Ford

Brian Fernau Confidential April 5, 2017
SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE
FORD MOTOR CREDIT COMPANY, LLC,

PLAINTIFF,
VS.
LENORE LUANN ALBERT-SHERIDAN, AND CASE No. 30-2015-

DOES 1 THROUGH 10, 00823254-CL-CL-CJC
DEFENDANTS.
LENORE ALBERT AKA LENORE LUANN

ALBERT-SHERIDIAN,
CROSS-COMPLAINANT,
VS.
FORD MOTOR CREDIT COMPANY, LLC, A

BUSINESS ENTITY, FORM UNKNOWN;
FRIENDLY FORD, A BUSINESS ENTITY,
FORM UNKNOWN; ET AL.,
CROSS-DEFENDANTS.
DEPOSITION OF
BRIAN FERNAU
Huntington Beach, California
Wednesday, April 5, 2017
Reported By:
Joyce Griffith
CSR No. 11010
NDS Job No. 191122
Network Deposition Services, Inc. ● networkdepo.com ● 866-NET-DEPO Page 1

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 1 APPEARANCES OF COUNSEL:
2 COUNTY OF ORANGE 2
3 3 ADR SERVICES, INC.
4 BY: HONORABLE DENNIS S. CHOATE
5 FORD MOTOR CREDIT COMPANY, LLC, ) 4 Judge of the Superior Court (Ret.)
) 19000 MacArthur Boulevard
6 Plaintiff, ) 5 Suite 550
) Irvine, California 92612.
7 vs. ) Case No. 30-2015- 6 (714) 998-1190
) 00823254-CL-CL-CJC judgechoate@yahoo.com
8 LENORE LUANN ALBERT-SHERIDAN, ) 7
and DOES 1 through 10, ) 8 For the Plaintiff:
9 ) 9 LAW OFFICES OF LENORE ALBERT
Defendants. ) BY: LENORE ALBERT, ESQ.
10 ___________________________________) 10 7755 Center Avenue
LENORE ALBERT aka LENORE LUANN ) Suite 1100
11 ALBERT-SHERIDAN, ) 11 Huntington Beach, California 92647
) (714) 372-2264
12 Cross-Complainant, ) 12 lenorealbert@msn.com
) 13
13 vs. ) 14 For the Defendant:
) 15 SEVERSON & WERSON
14 FORD MOTOR CREDIT COMPANY, LLC; ) BY: KRISTIN L. WALKER-PROBST, ESQ.
a business entity, form unknown; ) 16 DAVID A. BERKLEY, ESQ.
15 FRIENDLY FORD, a business entity, ) 19100 Von Karman Avenue
form unknown; et al., ) 17 Suite 700
16 ) Irvine, California 92612
Cross-Defendants. ) 18 (949) 442-7110
17 ___________________________________) klw@severson.com
18 19 db@severson.com
19 DEPOSITION OF BRIAN FERNAU 20
20 Huntington Beach, California 21
21 Wednesday, April 5, 2017 22
22 23
23 24
24 Reported by: Joyce Griffith 25
CSR No. 11010
25 NDS Job No.: 191122
Page 1 Page 3
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 1 INDEX
2 COUNTY OF ORANGE 2
3 3 WITNESS:
4 4 BRIAN FERNAU
5 FORD MOTOR CREDIT COMPANY, LLC, ) 5 EXAMINATION PAGE
) 6 By Ms. Albert 6
6 Plaintiff, ) 7
) 8 EXHIBITS
7 vs. ) Case No. 30-2015- 9 MARKED DESCRIPTION PAGE
) 00823254-CL-CL-CJC 10 Exhibit 1 Lenore Albert's Notice of Deposition 17
8 LENORE LUANN ALBERT-SHERIDAN, ) for the Person Most Knowledgeable for
and DOES 1 through 10, ) 11 Plaintiff/Cross-Defendant Ford Motor
9 ) Credit Company, LLC
Defendants. ) 12
10 ___________________________________) Exhibit 2 Simple Interest Vehicle Contract 55
LENORE ALBERT aka LENORE LUANN ) 13 for Sale and Security Agreement
11 ALBERT-SHERIDAN, ) (Bates FMCC 0001800-FMCC 000185)
) 14
12 Cross-Complainant, ) Exhibit 3 State of Nevada Certificate of Title 73
) 15 (Bates FMCC 0061)
13 vs. ) 16 Exhibit 4 Contact History Report 78
) (Bates FMCC 0020-0034)
14 FORD MOTOR CREDIT COMPANY, LLC; ) 17
a business entity, form unknown; ) Exhibit 5 Contact History Report 78
15 FRIENDLY FORD, a business entity, ) 18 (Bates FMCC000106-FMCC000120)
form unknown; et al., ) 19 Exhibit 6 Friendly Ford Certificate for 104
16 ) Alarms/Accessories; Lojack Ancillary
Cross-Defendants. ) 20 Order Form; Products Not Selected
17 ___________________________________) (Bates FMCC 000189, FMCC000190,
18 21 FMCC000197)
19 DEPOSITION OF BRIAN FERNAU 22 Exhibit 7 Westminster Police Department Report 164
20 taken on Wednesday, April 5, 2017, at the Law (Bates ALB323-333)
21 Offices of Lenore Albert, 7755 Center Avenue, 23
22 Suite 1100, Huntington Beach, California, Exhibit 8 Temporary Restraining Order George 166
23 commencing at 10:20 a.m. and concluding at 24 Olivo (Bates ALB334-ALB345)
24 5:35 p.m., before Joyce Griffith, Certified 25
25 Shorthand Reporter No. 11010.
Page 2 Page 4
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1 EXHIBITS (CONTINUED) 1 Q What type of case was that?
2 MARKED DESCRIPTION PAGE
2 A It had to do in regard to a judgement.
3 Exhibit 9 Case Summary 168
(ALB346-ALB351)
3 Q Did you testify in court?
4 4 A Yes.
Exhibit 10 Emails 170 5 Q Do you recall which courthouse?
5 (Bates ALB385-ALB392) 6 A I do not.
6 Exhibit 11 Emails 172
7 Q Do you recall what city?
(Bates ALB393-394)
7 8 A I do not.
Exhibit 12 Photograph 172 9 Q Do you recall which state?
8 10 A Yes.
Exhibit 13 Web Page 176
9 (Bates ALB406)
11 Q Which state?
10 Exhibit 14 Experian Report 182 12 A California.
(Bates ALB478) 13 Q Do you recall the county that you testified in?
11 14 A No.
Exhibit 15 Photographs 183
15 Q Was it in southern California or northern
12 (Bates ALB553-AMB554)
13 Exhibit 16 Photographs 183 16 California?
14 17 A Southern California.
15 18 Q Was it in San Diego County?
16 19 A No.
17
20 Q Was it in Orange County?
18
19 21 A I do not remember.
20 22 Q Was it in Riverside County?
21 23 A I don't remember.
22 24 Q Was it in San Bernardino County?
23
25 A I don't remember.
24
25
Page 5 Page 7
1 HUNTINGTON BEACH, CALIFORNIA, WEDNESDAY, APRIL 5, 2017 1 Q Was it in Los Angeles County?
2 10:20 A.M. 2 A No.
3 3 Q So it's somewhere between Orange County and the
4 BRIAN FERNAU, 4 Inland Empire, in general?
5 having been first duly sworn, was 5 A Yes.
6 examined and testified as follows: 6 Q What kind of action was it?
7 7 A What do you mean?
8 EXAMINATION 8 Q Was it to collect on a judgement?
9 BY MS. ALBERT: 9 A I don't remember the exact specifics of the
10 Q Would you state and spell your name for the 10 case.
11 record? 11 Q Do you remember who the plaintiff was?
12 A Yes, my name is Brian, B-R-I-A-N, Fernau, 12 A That would be Ford Motor Credit Company.
13 F-E-R-N-A-U. 13 Q Do you remember who the defendant was?
14 Q And are you here today on behalf of Ford Motor 14 A No.
15 Credit Company to be their person most knowledgeable? 15 Q Did Ford Motor Credit Company keep any trial
16 A Yes. 16 papers?
17 Q Have you ever taken a deposition before? 17 A I would not know.
18 A I have not. 18 Q Who would you ask at Ford Motor Credit Company?
19 Q Have you ever testified in court before? 19 A Our legal department.
20 A Yes, I have. 20 Q After this deposition, could you ask your legal
21 Q When? 21 department if they still kept any papers on that case so
22 A The last time was last year. 22 that one could be produced so I would know what case you
23 Q Did you testify on behalf of Ford Motor Credit 23 actually testified in?
24 Company? 24 MS. WALKER-PROBST: Objection; not likely to lead
25 A Yes. 25 to the discovery of admissible evidence.
Page 6 Page 8

1 JUDGE CHOATE: You can rephrase the question. 1 Q As we sit here today, I'm entitled to your best
2 BY MS. ALBERT: 2 testimony. Do you understand?
3 Q After this deposition, would you be able to ask 3 A Yes.
4 your legal department if they still retained any of those 4 Q Although we want your best testimony, which might
5 papers? 5 include an estimate, I do not want you to guess. Do you
6 A Yes. 6 understand the difference between an estimate and a
7 Q If they had, will you produce them? 7 guess?
8 MS. WALKER-PROBST: Objection; possibly 8 A Yes.
9 attorney-client privilege, not likely to lead to the 9 Q Since you are testifying under penalty of perjury
10 discovery of admissible evidence. 10 here today, if you change your answer later, do you
11 JUDGE CHOATE: You can go on from there. 11 understand that I can use the fact later at trial that you
12 THE WITNESS: Okay. Can you ask the question 12 have, in fact, later changed your answer?
13 again? I'm sorry. 13 A Yes.
14 BY MS. ALBERT: 14 Q You are here representing Ford Motor Credit
15 Q If the legal department kept a trial brief, any 15 Company, LLC, correct?
16 trial testimony or your deposition or anything else in 16 A Yes.
17 that case that would identify the case, would you produce 17 Q Are you also here representing Ford Credit
18 that? 18 Company?
19 MS. WALKER-PROBST: Objection; calls for 19 MS. WALKER-PROBST: I'm sorry? Could you repeat
20 speculation. 20 the question.
21 JUDGE CHOATE: Sustained. 21 (The record was read by the court reporter)
22 THE WITNESS: Do I answer? 22 MS. WALKER-PROBST: You can answer.
23 MS. WALKER-PROBST: No. 23 THE WITNESS: Yes.
24 JUDGE CHOATE: You're asking him about legal 24 BY MS. ALBERT:
25 documents, something like that, in the custody of the 25 Q Have you gone through any documents in order to
Page 9 Page 11
1 legal department; is that what you are asking for? 1 prepare for this deposition today?
2 MS. ALBERT: Because he said he can't remember 2 A I did.
3 the case that he testified in, so I -- 3 Q What documents did you review in preparation for
4 JUDGE CHOATE: I heard that. That's sustained. 4 your deposition today?
5 Let's move on. 5 A I went through a plethora of documents.
6 BY MS. ALBERT: 6 Q Did you go through the documents that were
7 Q Do you recall if it was federal court or state 7 produced in discovery?
8 court? 8 A You would have to show them to me. Like I said,
9 A It was state court. 9 I went through a lot of documents.
10 Q Since you never had your deposition taken, I want 10 Q Did you ask anyone that works at Ford Motor
11 to give you some admonitions. 11 Credit Company any questions or interview them in order to
12 Although you are sitting here, not in court, you 12 prepare for today's testimony?
13 are still under penalty of perjury. Do you understand 13 A I did.
14 that? 14 Q Who did you interview?
15 A Yes. 15 A I interviewed a COM.
16 Q And although we are sitting here in a proceeding 16 Q What is a COM?
17 of your deposition, at any time you can take a break if 17 A It is a manager.
18 you are thirsty, if you are hungry or if you want to 18 Q What does COM stand for?
19 consult with counsel. Do you understand that? 19 A I apologize. I'm drawing a blank on the
20 A Yes. 20 acronym.
21 Q However, if we are in the middle of a question 21 Q Do you remember the manager's name?
22 that I have asked and you haven't answered it yet, you may 22 A Yes.
23 take a break after you have answered that question. Do 23 Q What was the manager's name?
24 you understand? 24 A Olivia Zapeda.
25 A Yes. 25 COM stands for Center Operations Manager.
Page 10 Page 12

1 Q Other than Olivia Zapeda, did you interview 1 buyers, I have been a discounter, I supervised the
2 anyone else? 2 discounters, worked first payment defaults, customer
3 A No. 3 service, along with I worked skip accounts, just to name a
4 Q How long did your interview with Olivia Zapeda 4 couple.
5 last? 5 Q What year did you start working for Ford Motor
6 A I didn't keep track of the time. 6 Credit Company?
7 Q What are the job duties of a COM manager? 7 A 2000.
8 A For Olivia? 8 Q When you started working for Ford Motor Credit
9 Q Yes. 9 Company, did you start at the Irvine office?
10 A She is over the skip department. 10 A No.
11 Q For the record, what is the skip department? 11 Q When you first started working for Ford Motor
12 A It is part of the customer service department. 12 Credit Company in 2000, where did you first start out?
13 Q Is she a supervisor? 13 A In the Orange branch.
14 A Yes. 14 Q What was your title when you first started at
15 Q Do you know how long she has been working at Ford 15 Ford Motor Credit Company?
16 Motor Credit? 16 A Investigator.
17 A I do not. 17 Q What did you investigate?
18 Q Do you work at Ford Motor Credit Company? 18 A I did verifications for -- I did credit
19 A I do. 19 application verifications.
20 Q What is your title? 20 Q Do you currently supervise any employees as the
21 A My title is Financial Service Specialist. 21 financial service specialist?
22 Q What are your job duties as financial service 22 A No.
23 specialist? 23 Q Who is your supervisor?
24 A I have a lot of job duties. 24 A Lisa Divine.
25 Q Can you summarize them for us? 25 Q Could you spell Divine for us?
Page 13 Page 15
1 A I do performance consulting risk management, also 1 A Yes, D-I-V-I-N-E.

2 I'm called upon for court cases, I support the sales reps 2 Q What is her position?
3 out in the field, including being a liaison between our 3 A Financial Services Manager.
4 service center and the dealers, just to name a few. 4 Q Do you know who her supervisor is?
5 Q Where is your office located? 5 A Yes.
6 A In Irvine. 6 Q Who is her supervisor?
7 Q Could we have the address of the Irvine 7 A Tom --
8 address? 8 Q Do you know what his title is?
9 A Sure. 3 Glen Bell Way. 9 A Regional manager, I believe.
10 Q Could you spell Glen Bell? 10 Q Have you ever written any policies or procedures
11 A G-L-E-N, B-E-L-L, Way, Suite 200. 11 for Ford Motor Credit Company since you have worked there
12 Q How long have you worked as a financial service 12 from 2000 until today?
13 specialist for Ford Motor Credit Company? 13 A Yes.
14 A I don't remember the exact date. 14 Q What policies and procedures have you written for
15 Q Do you recall the year? 15 Ford Motor Credit Company?
16 A Approximately 2009, 2008. 16 A Wholesale takeovers.
17 Q Did you work for Ford Motor Credit Company in a 17 Q Other than wholesale takeovers, have you written
18 different capacity prior to that time? 18 any other types of policies and procedures?
19 A Yes. 19 A No.
20 Q What was your position at Ford Motor Credit 20 Q Do you work in the wholesale division or the
21 Company prior to around 2008, 2009? 21 retail division of Ford Motor Credit Company currently?
22 A I had many. 22 A Neither.
23 Q Walk us through them, please. 23 Q Which division of Ford Motor Credit --
24 A To the best of my recollection, I have been an 24 A I work in the sales division.
25 investigator, wholesale auditor, a buyer, supervised 25 MS. ALBERT: I'm going to hand you what we'll
Page 14 Page 16

1 have the reporter mark as Exhibit 1, Notice of Deposition 1 Expedition, SE VIN Number 1FMJK1J5XDEF15431?
2 for the Person Most Knowledgeable for Plaintiff 2 A Yes.
3 Cross-Defendant Ford Motor Credit Company. I'm going to 3 MR. BERKLEY: May I make a suggestion that we
4 ask you to review it and tell me if you have seen it 4 reference Ford Motor Credit Company as Ford Credit?
5 before. 5 MS. ALBERT: They are two different companies.
6 (Exhibit 1 was marked for identification and it 6 MR. BERKLEY: The plaintiff in this action is
7 is attached hereto) 7 Ford Motor Credit Company, LLC. To keep the record clear,
8 THE WITNESS: Yes, I have seen this document. 8 I believe we should call it Ford Credit.
9 BY MS. ALBERT: 9 JUDGE CHOATE: So ordered. There isn't going to
10 Q Are you the person most acknowledgeable for Ford 10 be any confusion about that.
11 Motor Credit Company with regard to the knowledge of the 11 MS. WALKER-PROBST: The motor company usually --
12 phone activity log that was produced, including but not 12 JUDGE CHOATE: Is separate. If a wheel falls off
13 limited to interpreting the terms and the code in that log 13 a car, it's a separate deal.
14 that was supplied by Ford Motor Credit Company and what 14 MS. WALKER-PROBST: It's going to be referenced
15 was redacted in the log? 15 in this case a little bit. What we usually do internally,
16 MS. WALKER-PROBST: Objection as to the latter 16 we call it Ford Credit. The dealer --
17 part of your question. 17 JUDGE CHOATE: It will be Ford Credit. If we get
18 THE JUDGE: Overruled. 18 into Ford Motor Company, we'll call it Ford Motor
19 THE WITNESS: I am knowledgeable in regard to the 19 Company.
20 phone and activity log that was produced. 20 MS. ALBERT: Then there's a stipulation that
21 BY MS. ALBERT: 21 liability would be the same, whether it's Ford Credit
22 Q Are you the person most knowledgeable for Ford 22 versus Ford Motor Credit Company?
23 Motor Credit Company with regard to the assignment from 23 MS. WALKER-PROBST: No. We don't represent Ford
24 Friendly Ford and purported breach alleged by Ford Motor 24 Motor Company.
25 Credit Company in its complaint? 25 JUDGE CHOATE: I don't want to go too far in
Page 17 Page 19
1 A I am familiar with the assignment from Friendly 1 this. She is saying Ford Motor Credit.
2 Ford, but there was no breach. 2 MS. WALKER-PROBST: Ford Motor Credit Company is
3 Q Are you familiar with the complaint that Ford 3 the same thing at Ford Credit.
4 Motor Company filed in this case? 4 MS. ALBERT: And there's a stipulation on the
5 A That Ford Motor Company filed? 5 record that liability as to Ford Credit would be the same
6 Q That Ford Motor Credit Company filed in this 6 as to Ford Motor Credit Company?
7 case. 7 MS. WALKER-PROBST: Yes.
8 A In what case? 8 BY MS. ALBERT:
9 Q In this action, did you know that Ford Motor 9 Q Are you the person most knowledgeable for Ford
10 Credit Company filed a complaint in this case? 10 Motor Credit Company about the registration and perfecting
11 A Yes. 11 of title and what was imperfect as noted in the phone
12 Q Are you familiar with the allegations that Ford 12 activity log supplied by Ford Motor Credit Company in this
13 Motor Credit Company is claiming in this action? 13 case?
14 A Yes. 14 A I am knowledgeable in regard to what was notated
15 Q Are you prepared to testify as to the underlying 15 on the phone/activity log.
16 facts with regard to the allegations Ford Motor Credit 16 Q Are you the person most knowledgeable about Ford
17 Company has made in its complaint in this case? 17 Motor Credit Company's hiring a repossession company to
18 A Yes. 18 locate and retrieve the vehicle?
19 Q Are you the person most knowledgeable about the 19 A Yes.
20 repossession of Ms. Albert's former 2013 Ford Expedition 20 Q Are you the person most knowledgeable about the
21 SE VIN Number 1FMJK1J5XDEF15431? 21 communications, whether written or oral, between Ford
22 A I am knowledgeable about the repossession. 22 Motor Credit Company and Ms. Albert about her loan?
23 Q Now, that's actually a long phrase to say every 23 A Yes.
24 time in this deposition, so would you agree that if I use 24 Q Are you the person most knowledgeable about the
25 the word "vehicle," we would be referring to the 2013 Ford 25 relationship Ford Motor Credit Company had with Friendly
Page 18 Page 20

1 Ford? 1 of consigned to it, correct, as if we were in a --
2 A In regard to the assignment, yes. 2 A I would not call it an consignment, but yes, it
3 Q What about in regard to the flooring agreement? 3 is lending.
4 MS. WALKER-PROBST: Obviously, this is subject to 4 Q Within the finance plans that you sent last
5 all of our objections that we served. Assuming facts 5 night, it refers to the flooring agreement, correct?
6 regarding a floor loan, not likely to lead to the 6 MS. WALKER-PROBST: Objection as to "finance
7 discovery of admissible evidence. 7 plans." Do you mean the policy that you are looking at?
8 JUDGE CHOATE: You need to identify the 8 THE WITNESS: I would have to see what you are
9 objections. If this goes back to court, you can't just 9 referencing.
10 say "all the objections." 10 BY MS. ALBERT:
11 MS. WALKER-PROBST: Okay. Maybe I should attach 11 Q I am handing you what is Bates stamped as FMCC
12 it as an exhibit. 12 1436 titled "Procedure." Maybe that's wrong. I'm sorry.
13 JUDGE CHOATE: Well, just say it, if you have a 13 I'm handing you what is Bates stamped FMCC 1391
14 hearsay objection or -- 14 to Bates stamp 1436 titled "Automotive Finance Plans."
15 MS. WALKER-PROBST: Not likely to lead to the 15 A Okay.
16 discovery of admissible evidence, compound. 16 Q Now, looking at the document that was sent to me
17 JUDGE CHOATE: What you are saying is it is 17 last night, isn't it true -- flip to the next page, it has
18 irrelevant? 18 a table of contents, correct?
19 MS. WALKER-PROBST: As to the flooring agreement. 19 JUDGE CHOATE: Did you send these documents?
20 JUDGE CHOATE: Overruled. 20 MS. WALKER-PROBST: Yes.
21 THE WITNESS: As to the flooring agreement, no. 21 JUDGE CHOATE: Last night?
22 BY MS. ALBERT: 22 MS. WALKER-PROBST: Yes.
23 Q Did you determine whether a flooring agreement 23 JUDGE CHOATE: I'm just listening to the
24 was in place between Ford Motor Credit Company and 24 question, and she said "the documents you sent me last
25 Friendly Ford? 25 night." I'm just asking you, did you send her any
Page 21 Page 23
1 MS. WALKER-PROBST: Objection; vague as to time, 1 documents last night?

2 not likely to lead to the discovery of admissible 2 THE WITNESS: No.
3 evidence. 3 JUDGE CHOATE: That's something attorneys do.
4 THE WITNESS: No. 4 THE WITNESS: Yes.
5 BY MS. ALBERT: 5 BY MS. ALBERT:
6 Q Last night I was emailed around 7:00 p.m. a 6 Q This document that I received last night from
7 policy and procedure by Ford Motor Credit Company. Did 7 your attorneys has a table of contents in it, correct?
8 you see that policy and procedure? 8 A Yes.
9 A I did. 9 Q In that table of contents, it talks about
10 Q Isn't it true that there's a reference to the 10 financing arrangements between the company and
11 flooring agreement in here? 11 repurchasing at the retail level, correct?
12 MS. WALKER-PROBST: Vague as to "the flooring 12 A Repurchasing at the retail level, so retail
13 agreement." 13 financing?
14 JUDGE CHOATE: I didn't quite hear that. Restate 14 Q Yes.
15 your question, I suppose. 15 A Yes.
16 BY MS. ALBERT: 16 Q Within that section of retail financing, it
17 Q Do you know what a flooring agreement is? 17 actually refers to the flooring agreements, correct?
18 A Yes, ma'am. 18 A Under retail financing?
19 Q What is a flooring agreement? 19 Q Yes.
20 A A flooring agreement is an agreement between a 20 Let's back up.
21 lending institution and the dealership where they provide 21 A In regard to wholesale financing, no.
22 financing to purchase vehicles from the manufacturer. 22 Q Not wholesale, retail?
23 Q So you would agree that it's basically an 23 A Oh, yes, it does -- the retail plan does describe
24 agreement that the dealership doesn't have to pay cash for 24 retail.
25 the vehicle while it sits on the lot. It's basically kind 25 Q We are still trying to get through the notice
Page 22 Page 24

1 here. Going back to the notice, are you the person most 1 BY MS. ALBERT:
2 qualified, knowledgeable, to discuss the flooring plan? 2 Q Do you know who the person most knowledgeable
3 MS. WALKER-PROBST: Objection; outside the scope 3 would be with regard to the right to loan funds?
4 of this lawsuit, not likely to lead to the discovery of 4 MS. WALKER-PROBST: Objection; vague, assumes
5 admissible evidence. 5 facts.
6 JUDGE CHOATE: Overruled. 6 JUDGE CHOATE: Do you know?
7 THE WITNESS: No. 7 THE WITNESS: I do not know the person's name.
9 Q Is there another person who works at Ford Motor 9 Q Do you know what their title within Ford Motor
10 Credit Company that could testify with regard to the 10 Credit Company would be?
11 flooring agreement? 11 A Center operations manager.
12 JUDGE CHOATE: I didn't hear the last three 12 Q Would that be wholesale again?
13 words. 13 A It would be in dealer credit.
14 MS. ALBERT: The flooring agreement. 14 Q Can I ask you why you didn't interview the COM of
15 MS. WALKER-PROBST: Calls for speculation. 15 dealer credit in preparation for your testimony today?
16 JUDGE CHOATE: Overruled. 16 A I did not interview the COM in dealer credit
17 THE WITNESS: Yes. 17 because I was focusing on the case itself and flooring and
18 BY MS. ALBERT: 18 all the different lending instruments that we have does
19 Q Who would that be? 19 not apply to what the focus was on.
20 MS. WALKER-PROBST: Calls for speculation, lacks 20 Q Why did you come to that conclusion?
21 foundation. 21 A Because we are dealing with a specific account
22 JUDGE CHOATE: Overruled. 22 and vehicle which is administered in one department, which
23 THE WITNESS: I don't know off the top of my 23 is customer service.
24 head. 24 Q Did customer service make the loan in this case
25 /// 25 to finance Ms. Albert's vehicle in 2013?
Page 25 Page 27
1 BY MS. ALBERT: 1 A No.

2 Q Do you know the title or position of the person 2 Q Did customer service deal with the registration
3 who would be working at Ford Motor Credit Company that 3 of Ms. Albert's vehicle that she purchased in 2013?
4 would be the person most knowledgeable to testify as to 4 MS. WALKER-PROBST: Objection; vague as to
5 the flooring department? 5 "deal."
6 A The department would be the wholesale 6 MS. ALBERT: As laid out in category 7.
7 department. 7 MS. WALKER-PROBST: Objection; vague as to "deal
8 Q Do you know the title of the supervisor over the 8 with."
9 wholesale department? 9 JUDGE CHOATE: Overruled.
10 A The COM, center operations manager. 10 THE WITNESS: To deal with the registration?
11 Q Would that be Olivia Zapeda? 11 Customer service is part of that department or, I'm sorry,
12 A No ma'am. 12 titling is part of that department
13 Q So, going on to the next part of the deposition 13 BY MS. ALBERT:
14 notice, are you the person most knowledgeable with regard 14 Q The assignment, right to assign between Friendly
15 to the right to loan funds, which is still part of 15 Ford and Ford Motor Credit Company, is that also a part of
16 Category 7? 16 customer service?
17 MS. WALKER-PROBST: Objection; vague. 17 A That's part of an agreement, an executed
18 MS. ALBERT: I'll rephrase. I think it's already 18 agreement between the dealer and Ford Credit.
19 written in Category 7. 19 Q But who deals with that? Is that customer
20 BY MS. ALBERT: 20 service?
21 Q Are you the person most knowledgeable about the 21 MS. WALKER-PROBST: Objection; vague as to "deals
22 right to loan funds between Ford Motor Credit Company and 22 with."
23 Friendly Ford, the dealership? 23 JUDGE CHOATE: Overruled.
24 A No. 24 THE WITNESS: It's an executed document. Are you
25 MS. WALKER-PROBST: Objection; vague. 25 asking me where it's housed?
Page 26 Page 28

1 MS. ALBERT: No. I'm asking you who supervised 1 title.
2 it? Who enforces it? 2 BY MS. ALBERT:
3 MS. WALKER-PROBST: Objection to the extent that 3 Q But are you the person most knowledgeable with
4 calls for attorney-client privilege. 4 regard to that registration process?
5 JUDGE CHOATE: Do you understand the question? 5 A Once again, Ford Credit is not responsible for
6 THE WITNESS: Not really. 6 the registration of individual contracts that they
7 JUDGE CHOATE: Restate the question. 7 purchase from dealerships. It is the dealership's
8 BY MS. ALBERT: 8 responsibility to ensure that it is titled and
9 Q Does customer service also handle the assignment 9 registered.
10 of title on a vehicle from Friendly Ford to Ford Motor 10 Q I understand that that might be your position and
11 Credit Company? 11 legal argument at trial, but my question is simply your
12 A The assignment is actually on a contract. 12 knowledge.
13 Q But contracts can't sign things or type things 13 Have you prepared yourself where you can testify
14 up, can they? 14 to questions with regard to sending the papers to the DMV
15 A Right. When we purchase the contract, we are 15 for registration purposes from April 29, 2013, through May
16 accepting the assignment, and that is done by 16 1, 2015?
17 discounting. 17 MS. WALKER-PROBST: Objection; assumes facts.
18 Q And is that also handled by the COM? 18 JUDGE CHOATE: Overruled. You were going to
19 A There's a COM over every department. 19 answer. Go ahead and give your answer again.
20 Q So did you interview the discounting COM? 20 THE WITNESS: Once again, Ford Credit does not
21 A No. 21 send paperwork to the DMV in the fifty states of the
22 Q Even though you didn't interview the person, the 22 United States. It is the dealership's responsibility and
23 COM in discounting, are you the person most knowledgeable 23 it's part of our agreement within our assignment that they
24 with regard to the assignment between Friendly Ford and 24 ensure registration and titling within a timely manner
25 Ford Motor Company? 25 upon purchase or assignment of a contract.
Page 29 Page 31
1 A Yes. 1 BY MS. ALBERT:

2 Q So when we are looking at Category 7, are you the 2 Q So is it your testimony today, binding Ford Motor
3 person most qualified or knowledgeable to testify to that 3 Credit Company, LLC, to this testimony, that Ford Motor
4 entire area, except for the right to loan the funds and 4 Credit Company, LLC, will not send registration papers to
5 the flooring agreement? 5 the DMV for titling purposes?
6 A Correct. 6 A Once again, it is our agreement with the
7 Q There is a last part to it that I didn't ask, but 7 dealership that we purchase the contracts and that they
8 I want to make sure I have it on the record. Are you the 8 ensure that all DMV paperwork is done correctly. We have
9 person most qualified to testify to the duty to send the 9 a follow-up log to ensure that it is done and we do
10 papers to the DMV for registration purposes from April 29, 10 follow-up with the dealership.
11 2013, through May 1, 2013? 11 Q That wasn't my question. My question was, does
12 MS. WALKER-PROBST: Objection; assumes facts. 12 Ford Motor Credit Company, binding Ford with your
13 That does not state that in the category. There's no word 13 testimony today, intentionally not send paperwork to the
14 "duty," that there's such a duty. 14 DMV in order to title and register a vehicle?
15 JUDGE CHOATE: That's a speaking objection. 15 MS. WALKER-PROBST: Objection; argumentative,
16 MS. WALKER-PROBST. I apologize. To the extent -- 16 vague, badgering the witness, cumulative.
17 JUDGE CHOATE: I understand, but -- do you 17 JUDGE CHOATE: Overruled on each.
18 understand the question? 18 THE WITNESS: We don't have the capacity, nor the
19 THE WITNESS: I do. 19 paperwork, in order to register a vehicle.
20 JUDGE CHOATE: Did you give an answer? 20 MS. ALBERT: I understand that might be your
21 THE WITNESS: I will give you an answer. 21 reason, but my question is truly a yes or no question.
22 Ford Credit does not have a duty to send papers 22 MS. WALKER-PROBST: Would you read the question
23 to the DMV for the registration of contracts that we 23 back?
24 purchase from dealerships. It's the dealership's 24 (The record was read by the court reporter)
25 responsibility per our agreement with them to perfect 25 MS. WALKER-PROBST: Objection; assumes facts.
Page 30 Page 32

1 JUDGE CHOATE: Do you have an understanding? 1 MS. WALKER-PROBST: Assumes facts.
2 THE WITNESS: No. 2 JUDGE CHOATE: Does anybody at Ford Credit know
3 JUDGE CHOATE: Next question? 3 what the security systems are?
4 BY MS. ALBERT: 4 THE WITNESS: No.
5 Q Going on to Category 8, are you the person most 5 BY MS. ALBERT:
6 knowledgeable about the personal property of Ms. Albert's 6 Q Are you the person most knowledgeable about Ford
7 that was in the vehicle on the day it was repossessed? 7 Credit's use of informants and third parties in collecting
8 A No. 8 or repossession of the vehicle?
9 Q Do you know who the person most knowledgeable 9 A Yes.
10 with regard to the personal property of Ms. Albert's that 10 Q Are you the person most knowledgeable as stated
11 was left in the vehicle on the day it was repossessed that 11 in Category 12 about how Ford Motor Credit Company came up
12 could testify in that area? 12 with the auction price for bidding on the vehicle and how
13 MS. WALKER-PROBST: Objection; assumes facts. 13 it ascertained monies were still due, including breakdown
14 THE WITNESS: Yes. 14 of all charges?
15 BY MS. ALBERT: 15 MS. WALKER-PROBST: Objection; assumes facts.
16 Q Who would that be? 16 JUDGE CHOATE: Overruled.
17 A Dedicated Recovery. 17 THE WITNESS: We do not set an auction price.
18 Q Going on to Category 9, are you the person most 18 BY MS. ALBERT:
19 knowledgeable about the payments made towards the purchase 19 Q But are you the person most knowledgeable that
20 of the 2013 Ford Expedition SE VIN 1FM -- 20 can give the facts with regard to the auction price, the
21 JUDGE CHOATE: We have agreed it's to be called 21 bidding, and how it ascertained monies were still due,
22 "the vehicle." 22 including breakdown of all charges?
23 BY MS. ALBERT: 23 A Yes.
24 Q The vehicle and fees and costs are other charges 24 Q Are you the person most knowledgeable about
25 for Ford Motor that were charged? 25 communications Ford Credit had with Monica Jones and other
Page 33 Page 35
1 A Yes. 1 third-party informants, including the identity of those

2 Q Going to Category 10, are you the person most 2 persons and the substance of those conversation?
3 knowledgeable and prepared to testify about the security 3 A Yes.
4 system installed in the vehicle, including but not limited 4 Q Are you the person most knowledgeable about the
5 to the Lojack and Hijack? 5 communications Ford Credit had with Friendly Ford about
6 MS. WALKER-PROBST: Objection, vague. 6 the vehicle?
7 JUDGE CHOATE: Overruled. 7 A Yes.
8 THE WITNESS: I'm aware of it. 8 Q Including the identity of those persons and the
9 BY MS. ALBERT: 9 substance of those conversations?
10 Q Did you prepare yourself to testify in that area 10 A Yes.
11 today? 11 Q We are on Category 15 now. Are you the person
12 A About the security system itself? 12 most knowledgeable about the communications Ford Credit
13 Q Yes. 13 had with Dedicated Recovery Service about the vehicle
14 A No. 14 and/or Ms. Albert, including the identity of those persons
15 Q Are you prepared to testify whether or not the 15 and the substance of those conversations?
16 security systems were there? 16 A Yes.
17 A Yes. 17 Q Are you the person most knowledgeable about the
18 Q But you are not prepared to testify what the 18 loan, including but not limited to the application of
19 security systems did? 19 payments, the payment of fees, costs, advances, charges,
20 A Correct. 20 repossessions, UCC compliance, Rees-Levering Compliance,
21 Q Do you know who at Ford Motor Company could 21 the font size of type used on the loan documents,
22 testify as to what those security systems did? 22 identification of all papers contained in the original
23 MS. WALKER-PROBST Can I have the question 23 loan documents, all documents evidencing title,
24 again? 24 assignments, endorsements, including dates, and papers
25 (The record was read by the court reporter) 25 sent to the DMV?
Page 34 Page 36

1 MS. WALKER-PROBST: Objection; compound, calls 1 THE WITNESS: I'm sorry. Can you restate the
2 for legal conclusion -- 2 question, please?
3 JUDGE CHOATE: Speaking in a general sense, 3 BY MS. ALBERT:
4 without the fifteen sub-parts. 4 Q Are you the person most knowledgeable with regard
5 THE WITNESS: Overall, yes, I'm the most 5 to those communications?
6 knowledgeable when it comes to the payments, the fees, the 6 MS. WALKER-PROBST: Objection; vague as to "those
7 advances, the charges, the repossession, in regards to the 7 communications."
8 Rees-Levering compliance, font size -- you know, that is 8 JUDGE CHOATE: What do you mean by "Those
9 required, along with all the documents evidencing -- 9 communications"?
10 required by the DMV, no. It depends on if you want to 10 BY MS. ALBERT:
11 break it down. We can go line item by line item. 11 Q Are you most knowledgeable as listed in Category
12 BY MS. ALBERT: 12 16 of the communications between Friendly Ford and Ford
13 Q Who would be the person most knowledgeable with 13 Motor Credit Company with regard to registering the
14 regard to the DMV? 14 vehicle?
15 MS. WALKER-PROBST: Objection; foundation, calls 15 A Yes.
16 for speculation, vague. 16 Q Category 17, are you the person most
17 JUDGE CHOATE: Overruled. 17 knowledgeable about Ford Credit's policies and procedures
18 THE WITNESS: That would be the dealership or the 18 on customer privacy rights that were in effect from April
19 DMV. 19 29, 2013, to April 30, 2015?
21 Q Who at Ford Motor Credit Company would be the 21 Q Have you reviewed those policies and
22 person most knowledgeable to all the conversations that 22 procedures?
23 occurred between Ms. Albert and Ford Credit with regard to 23 A I'd have to re-look at them. I have gone through
24 registering the vehicle with the DMV? 24 many policies and procedures.
25 A That would be me. 25 Q Did you go through the policies and procedures in
Page 37 Page 39
1 Q And who would be the person most knowledgeable to 1 preparation of your testimony today?
2 all the conversations between Ford Credit and Friendly 2 A I did.
3 Ford with regard to the Las Vegas litigation and 3 Q When did you review those?
4 registering the car with the DMV? 4 A Multiple days.
5 MS. WALKER-PROBST: Objection; assumes facts, 5 Q Was it a week ago? Was it yesterday?
6 calls for attorney-client privilege potentially. There's 6 A I reviewed some last week, this week, last
7 a lawsuit by Friendly Ford to the extent there is 7 night.
8 communication with lawyers. 8 Q Do you know why I didn't receive them until
9 JUDGE CHOATE: That's right, exclusive of any 9 approximately 8:00 p.m. two nights ago?
10 communication with any law firm or any lawyer, can you 10 MS. WALKER-PROBST: Objection; assumes facts,
11 answer that question? 11 lacks foundation.
12 MS. WALKER-PROBST: If you can't answer it 12 JUDGE CHOATE: Overruled.
13 without referring to lawyers -- 13 THE WITNESS: I do not.
14 THE WITNESS: I cannot. 14 BY MS. ALBERT:
15 BY MS. ALBERT: 15 Q Number 18, are you the person most knowledgeable
16 Q It's in your customer service notes? 16 about Ford Motor Credit Company's policies and procedures
17 A Well, we have knowledge of the lawsuit, yes. 17 on customer collections in effect from April 29, 2013,
18 Q But are you the person most knowledgeable as to 18 through April 30, 2015?
19 what those communications were? Those were business 19 A Yes.
20 decisions. If you are talking to a paralegal even or if 20 Q Are you the person most knowledgeable with regard
21 you are talking to Friendly Ford, that is not 21 to the policies and procedures on customer repossession in
22 attorney-client privilege. 22 effect from April 29, 2013, through April 30, 2015?
23 MS. WALKER-PROBST: Objection -- 23 A Yes.
24 JUDGE CHOATE: Let's just ask the question of the 24 Q Are you the person most knowledgeable about Ford
25 witness and he will answer the question, if he can. 25 Credit's policies and procedures on perfecting title as
Page 38 Page 40

1 a lienholder in effect from April 29, 2013, through April 1 MS. WALKER-PROBST: Objection; vague.
2 30, 2015? 2 JUDGE CHOATE: Overruled.
3 A Yes. 3 THE WITNESS: You are referencing the lawsuit
4 Q Are you the person most knowledge about Ford 4 between Friendly Ford and the plaintiff?
5 Credit Company's policies and procedures on automobile 5 MS. ALBERT: Yes.
6 financing in effect from April 29, 2013, through April 30, 6 THE WITNESS: I have knowledge of it.
7 2013? 7 BY MS. ALBERT:
8 MS. WALKER-PROBST: Objection; overbroad. 8 Q Are you the person most knowledgeable about the
9 JUDGE CHOATE: Overruled. 9 identity and contact information for employees, vendors or
10 THE WITNESS: Yes. 10 agents that have personal knowledge of the events and
11 BY MS. ALBERT: 11 occurrences laid out in the cross-complaint or in the
12 Q Are you the person most knowledgeable about Ford 12 complaint in this action that have not yet been disclosed
13 Credit's policies and procedures on vehicle registration 13 in discovery?
14 issues in effect from April 29, 2013, to April 30, 14 MS. WALKER-PROBST: Objection; overbroad,
15 2013? 15 vague.
16 A We don't have exact policies and procedures for a 16 JUDGE CHOATE: Overruled. It's an "are you
17 specific vehicle in regards to registration. 17 aware" question. Most of these --
18 Q I saw some when I reviewed them. 18 MS. WALKER-PROBST: But it references the
19 A Well, that's -- 19 pleadings and --
20 MS. WALKER-PROBST: There's no question. 20 JUDGE CHOATE: It doesn't make any difference.
21 BY MS. ALBERT: 21 Just say no, yes, or I don't know.
22 Q Is it your testimony today that you do not 22 MS. ALBERT: He could have information about my
23 believe that the policies and procedures that you produced 23 pleadings and --
24 so far in discovery do not contain any policies and 24 JUDGE CHOATE: Let's go. Ask your next question.
25 procedures with regard to registration issues? 25 ///
Page 41 Page 43
1 MS. WALKER-PROBST: Objection; misstates his 1 BY MS. ALBERT:

2 testimony. 2 Q Are you the person most knowledgeable as to why
3 JUDGE CHOATE: Overruled. 3 Ford Credit Company does not believe Ms. Albert was
4 THE WITNESS: Would you repeat the question? 4 damaged as a result of Ford Motor Credit Company's action
5 (The record was read by the court reporter) 5 entitling her to an award of money damages?
6 THE WITNESS: We do have policies and procedures 6 MS. WALKER-PROBST: Objection; calls for legal
7 in regard to perfecting of the title, but not on a 7 conclusion.
8 specific vehicle. 8 JUDGE CHOATE: Overruled.
9 BY MS. ALBERT: 9 THE WITNESS: Yes.
10 Q Are you the person most knowledgeable about Ford 10 BY MS. ALBERT:
11 Credit Company's policies and procedures on car dealership 11 Q Are you the person most knowledgeable as to why
12 titling or registration issues in effect from April 29, 12 Ford believes Ms. Albert owes Ford money?
13 2013, to April 30, 2013? 13 A What number is that?
14 A Yes. 14 Q Number 26.
15 Q Are you the person most knowledgeable of any loss 15 A Yes.
16 mitigation attempts with Friendly Ford and Ford Motor 16 Q Are you the person most knowledgeable to identify
17 Company? 17 the person or persons who created and implemented the
18 MS. WALKER-PROBST: Objection; calls for legal 18 policies and procedures that will be discussed at this
19 conclusion and vague as to "loss mitigation attempts." 19 deposition, which are simply the policies and procedures
20 JUDGE CHOATE: Overruled. 20 that you produced so far in this case?
21 THE WITNESS: There was no loss mitigation 21 MS. WALKER-PROBST: Objection; attorney-client
22 attempts with Friendly Ford and Ford Motor Credit 22 privilege, work product.
23 Company. 23 JUDGE CHOATE: Overruled.
24 BY MS. ALBERT: 24 Are you aware or not?
25 Q Do you know what a loss mitigation attempt is? 25 THE WITNESS: I am aware of --
Page 42 Page 44

1 JUDGE CHOATE: That's a yes? 1 Q Where is Ford Motor Credit Company's office
2 THE WITNESS: Yes. 2 located where it does enter into financial arrangements
3 MS. WALKER-PROBST: Just to be clear, we are not 3 with borrowers who are purchasing a car?
4 discussing -- 4 A Colorado Springs Service Center.
5 JUDGE CHOATE: You can clear it up. These are 5 Q Does the Colorado Springs Service Center do
6 "Are you aware" questions. 6 anything, other than initiate the financial contracts
7 THE WITNESS: Our policies and procedures are 7 between Ford Motor Credit Company and the borrowers who
8 written by the Center of Excellence Group and there are a 8 are purchasing cars?
9 multitude of different ones of these groups that write our 9 A Yes, ma'am.
10 policies and procedures, which is a living document. I 10 Q What else do they do?
11 mean, I'm aware of these groups, these Center of 11 A I can name a multitude of things, but I'm sure
12 Excellence groups. I do not know each and every person in 12 they do much more. They administer the wholesale,
13 every group. 13 origination, which is the purchasing of contracts, the
14 BY MS. ALBERT: 14 discounting, which is the funding of the contracts. They
15 Q Are you aware of who supervised the employees to 15 also do the customer service, along with dealer credit,
16 ensure that those policies and procedures that -- are you 16 which encompasses additional financing above and beyond
17 the person most knowledgeable to be able to identify the 17 the purchasing of individual contracts.
18 supervisor or the employees that ensured that the policies 18 Q Does Ford Motor Credit Company perfect title out
19 and procedures that we will discuss at the deposition 19 of any office located in California?
20 today were followed? 20 A No.
21 MS. WALKER-PROBST: Calls for speculation. 21 Q Where does Ford Motor Credit Company perfect
22 JUDGE CHOATE: I don't know what I missed out on, 22 title?
23 what you discussed before, but I don't know how he's 23 A They do not.
24 supposed to know that. 24 Q Does Ford Motor Credit Company contract with
25 THE WITNESS: No. 25 outside vendors to perfect title?
Page 45 Page 47

2 Q Are you the person most knowledgeable to be able 2 Q Does Ford Motor Credit Company collect payments
3 to identify the supervisors or the policies that ensured 3 on loans that are given to car buyers out of any office
4 the policies and procedures were discussed with regard to 4 located in California?
5 the policies and procedures that you produced in 5 A I do not know.
6 discovery? 6 Q Does Ford Motor Credit Company authorize any
7 A No, not the individual supervisors. 7 repossessions out of any office located in California?
8 Q Is Ford a business located within California? 8 A No.
9 MS. WALKER-PROBST: Objection; vague, calls for a 9 Q Do you know what location for Ford Motor Credit
10 legal conclusion. 10 Company that actually does authorize repossessions?
11 JUDGE CHOATE: Overruled. 11 A Colorado Springs Service Center for California.
12 THE WITNESS: We do business in California. 12 Q You said "of California"?
13 BY MS. ALBERT: 13 A For California.
14 Q Do you have physical offices in California? 14 Q Did you interview any employees that are located
15 A Yes. 15 at the Colorado Springs Service Center in preparation for
16 Q Does Ford Motor Credit Company finance any cars 16 your deposition testimony today?
17 out of any of the offices that are located in 17 A Yes.
18 California? 18 Q Who did you interview?
19 A Can you be more specific when you say "finance"? 19 A Olivia Zapeda.
20 Q Enter into financial agreements. I'll re-ask it. 20 Q Did you graduate from high school?
21 A Okay. 21 A I did.
22 Q Does Ford Motor Credit Company enter into 22 Q Did you graduate from college?
23 financial contracts with customers purchasing a car in 23 A No.
24 offices located in California? 24 Q Has Ford Motor Credit Company given you any
25 A No. 25 specialized training since you worked there since 2000?
Page 46 Page 48

1 A Quite a bit. 1 Q So you don't recall without seeing it if you have
2 Q Has Ford given you any specialized training with 2 actually read your complaint?
3 regard to registration of vehicles? 3 A I have read a lot of documents, ma'am. I
4 A No. 4 apologize.
5 Q Has Ford Motor Credit Company given you any 5 Q Okay, fair enough.
6 specialized training with regard to perfecting title on 6 Did Friendly Ford sell a vehicle to Ms. Albert on
7 vehicles? 7 April 29, 2013, in this action?
8 A No. 8 A I do know that there was a sale and I know it was
9 Q Has Ford Motor Credit Company given you any 9 in 2013. I do not remember the exact date without looking
10 special training with regard to repossessing vehicles? 10 at the account notes.
11 A Yes. 11 Q When did Ford Motor Credit Company finance the
12 Q Has Ford Motor Credit Company given you any 12 sale of that vehicle that Ms. Albert purchased from
13 special training as to collecting overdue accounts? 13 Friendly Ford in 2013?
14 A Yes. 14 A Yes, ma'am, we did purchase that contract from
15 Q Has Ford Motor Credit Company given you any 15 the dealership.
16 special training with regard to financing car loans? 16 Q When did Ford Credit purchase the contract from
17 A Yes. 17 the dealership?
18 Q Has Ford Motor Company given you any specialized 18 A I'd have to see the account notes in order to
19 training in using informants or third-parties to locate 19 give you the exact date.
20 cars, other than a licensed repossession agency? 20 Q Was it at or near the time that the vehicle was
21 A Specifically, just in regard to utilizing 21 sold?
22 informants, no. 22 A It was close.
23 Q When was the last time you received any 23 Q How much did Ford Motor Credit Company finance?
24 specialized training from Ford Motor Credit Company? 24 A I do not remember that off the top of my head.
25 A Two weeks ago. 25 Q In 2015, did Ford Motor Credit Company direct a
Page 49 Page 51
1 Q What was that in regard to? 1 repossession company to repossess the vehicle Ms. Albert
2 A Diversity. 2 bought from Friendly Ford in 2015?
3 Q When was the last time you received any special 3 A In 2015?
4 training from Ford Motor Credit Company with regard to 4 Q Yes.
5 collecting on car loans? 5 A Yes.
6 A I do not remember. 6 Q Did Ford Motor Credit Company hire a company to
7 Q Can you give us an estimate as to what year? 7 repossess Ms. Albert's vehicle that you financed in
8 A I cannot. I'm sorry. 8 2015?
9 Q Can you tell us if it was within the past five 9 A I'm sorry. Say that again.
10 years? 10 Q In 2015, did Ford Motor Credit Company hire a
11 A No, it was not within the past five years. 11 company to repossess Ms. Albert's vehicle that you had
12 Q Can you tell us the last time you received 12 previously financed?
13 specialized training with regard to car repossessions by 13 A Yes, ma'am.
14 Ford Motor Credit Company? 14 Q In 2015, was Ms. Albert's vehicle that you
15 A I cannot. 15 financed actually repossessed?
16 Q Do you know whether that was within the past five 16 A Yes, it was.
17 years? 17 Q After that vehicle was repossessed by Ford Motor
18 A It was not within the last five years. 18 Credit Company, the company that it hired to do the
19 Q Do you recall the last time you received any 19 repossession, did you then auction the vehicle?
20 specialized training from Ford Motor Credit Company with 20 MS. WALKER-PROBST: Objection; vague as to "you."
21 regard to financing? 21 JUDGE CHOATE: Overruled.
22 A Within the last three months. 22 THE WITNESS: Yes. The vehicle was auctioned
23 Q Have you read the complaint in this case that was 23 after the right to cure or the right to cure had
24 filed by Ford Motor Credit Company? 24 expired.
25 A Can I see it? 25 ///
Page 50 Page 52

1 BY MS. ALBERT: 1 Q Did Ford Motor Credit Company ever sign that
2 Q Was it a private auction or a public auction? 2 contract?
3 A It was a private auction. 3 A No.
4 Q For the record, what is a private auction? 4 MS. ALBERT: We are going to go to what's Bates
5 A It's called Open Lane, in which our Ford dealers 5 stamped as Exhibit 180 by Ford Motor Credit Company.
6 or our dealership body are the ones that are originally 6 MS. WALKER-PROBST: Is this a good time to take a
7 invited to come and bid on those vehicles, along with some 7 break?
8 others. If they do not sell, then it's opened up to the 8 MS. ALBERT: Yes, we can take a break.
9 public. 9 (Recess from 11:30 a.m. through 11:45 a.m.)
10 Q Are dealerships just located in California 10 JUDGE CHOATE: Do you understand that you are
11 allowed to bid or is it open interstate? 11 still under oath and obligated to tell the truth in all
12 A It's open to the entire United States. 12 particulars?
13 Q Do you have to be a Ford dealership in order to 13 THE WITNESS: Yes, sir.
14 bid on the vehicle? 14 MS. ALBERT: I'd like to mark as my next exhibit
15 A For the original offering, yes. 15 a document entitled "Simple Interest Vehicle Contract for
16 Q Was there anything past an original offering in 16 Sale and Security Agreement." It is Bates stamped FMCC
17 this case when Ms. Albert's vehicle was put up for private 17 00180 through FMCC 000185.
18 auction? 18 (Exhibit 2 was marked for identification and it
19 A I'm sorry, was there any what? 19 is attached hereto)
20 Q Beyond, did it open up to other dealerships other 20 BY MS. ALBERT:
21 than the original Ford dealerships or did it sell right 21 Q Have you seen this document before?
22 away upon the first offering? 22 A I have.
23 A I do not know. 23 Q Do you know what this document is?
24 Q After Ford Motor Credit Company repossessed the 24 A I do.
25 vehicle and resold it through private auction to another 25 Q What is this document that we have marked as
Page 53 Page 55
1 Ford dealership, did Ford Credit then bring an action 1 Exhibit 2 to your deposition?
2 against Ms. Albert to sue for a deficiency judgment in the 2 A It is a retail sales contract.
3 approximate amount of $3,500? 3 Q Is this the sales contract you were referring to
4 A Yes. 4 with regard to your testimony prior to the break?
5 Q Was that lawsuit based on a written contract? 5 A Yes.
6 A Yes. 6 Q Is this the contract that Ford Motor Credit
7 Q Can you describe that written contract for the 7 Company is relying upon in asserting its claim in this
8 record? 8 action?
9 A The security instrument that would enforce that 9 A Yes.
10 would actually be the contract that was executed at the 10 Q If you look at the top left-hand corner, who is
11 dealership between the purchaser and the dealership, in 11 the buyer?
12 that we took in and purchased from the dealership on 12 A That would be Lenore Luann Albert Sheridan.
13 assignment. 13 Q Who is the creditor?
14 Q Was Ford Motor Credit Company a party to that 14 A Friendly Ford.
15 contract? 15 Q Are there signatures on this document?
16 MS. WALKER-PROBST: Objection; calls for a legal 16 A There are signatures on this document.
17 conclusion, vague as to time. 17 Q For the record, what is the Bates stamp page
18 JUDGE CHOATE: Overruled. If you know, you can 18 number that shows the signatures on this document?
19 answer. 19 MS. WALKER-PROBST: Objection; document speaks
20 THE WITNESS: I don't know what you mean by "a 20 for itself.
21 party." 21 JUDGE CHOATE: You can tell us the number.
22 BY MS. ALBERT: 22 THE WITNESS: There are signatures on FMCC 000181
23 Q Was Ford Motor Credit Company named in that 23 and FMCC 00182.
24 contract that you just referred to? 24 BY MS. ALBERT:
25 A No. 25 Q Is there a Ford Credit Motor Company signatory
Page 54 Page 56

1 anywhere that you have seen on either FMCC 000181 or 1 A Up at the top?
2 182? 2 Q I'm looking to see if -- under section C, where
3 A No, there's no signatures by Ford Credit. 3 it says "Itemization of amount financed," it has a vehicle
4 Q Was there a written assignment of this contract 4 selling price of $56,238.87. Do you see that?
5 between Friendly Ford and Ford Motor Credit Company? 5 A Yes.
6 A Yes, there is an assignment. 6 Q Under that it says "Documentary Fee," do you see
7 Q What is the title of the assignment? 7 that?
8 A It's called "Assignment." 8 A Yes.
9 Q What Bates number are you looking at? 9 Q What is the amount of the documentary fee?
10 A The bottom right, FMCC000184. 10 A $415.72.
11 Q What paragraph do you allege gives an assignment 11 Q Do you know what that documentary fee is?
12 to Ford Motor Credit Company making them a party to this 12 A I do.
13 contract? 13 Q What is the documentary fee for?
14 MS. WALKER-PROBST: Objection; calls for legal 14 A The documentary fee is a fee charged by the
15 conclusion. 15 dealership to the purchaser of a vehicle.
16 JUDGE CHOATE: Overruled. 16 Q My question is, what is the charge for?
17 THE WITNESS: There's no designation of the 17 A The charge is essentially to offset the handling
18 paragraph itself. It's in the middle of the page and goes 18 of not only their documents, but also offsets fixed ops
19 all the way through paragraph 4. 19 costs, along with semi-fixed ops.
20 BY MS. ALBERT: 20 Q For the dealer?
21 Q When did Ford Motor Credit Company obtain this 21 A For the dealer.
22 sales contract, which we have marked as Exhibit 2? 22 I'm sorry. When I said fixed ops, I mean fixed
23 A When did we receive the contract? 23 operations, and when I say semi-fixed ops, I mean
24 Q Yes. 24 semi-fixed operational costs.
25 A From the dealership? 25 Q Is there a definition of what the documentary fee
Page 57 Page 59
1 Q Yes. 1 is anywhere in this contract?

2 A I do not know that exact date. 2 A I don't know.
3 Q Was it received from the dealership? 3 MS. WALKER-PROBST: You answered the question.
4 A Yes. 4 THE WITNESS: I don't know.
5 Q After Ford Motor Credit Company received this 5 BY MS. ALBERT:
6 contract from the dealership, what did it do? 6 Q If you go down, you see that there are two more
7 A We purchased the contract from the dealership. 7 entries. One says "SECSY $495," do you see that?
8 Q What did you do in order to effectuate a purchase 8 A Yes, ma'am.
9 of the contract from the dealership, Friendly Ford in this 9 Q Do you know what that $495 is for?
10 case, in order to purchase this contract, which is marked 10 A It's an abbreviation for security system.
11 as Exhibit 2? 11 Q Below that, there's another figure, a cost of
12 A We paid the dealership money for the contract. 12 $595. Do you see that?
13 Q Do you know how much Ford Motor Credit Company 13 A Yes.
14 paid Friendly Ford for this contract, which is marked as 14 Q It says "Lojack," do you know what that is for?
15 Exhibit 2? 15 A Yes, it's for Lojack.
16 A I don't know the exact dollar amount off the top 16 Q Was Ms. Albert charged for the cost of a security
17 of my head. I would have to see the accounting. 17 system in the amount of $495?
18 Q Is this the entire sales contract, which is 18 A Yes.
19 marked at Exhibit 2? 19 Q Was Ms. Albert charged the cost of $595 for a
20 A Yes. 20 Lojack system?
21 Q Are there any pages missing? 21 A Yes.
22 A Not to my knowledge. 22 Q Was Ms. Albert charged $415.72 for the
23 Q If you look at the top left-hand side of the 23 documentary fee?
24 first page, do you see where it says that there is a 24 A Yes.
25 document fee? 25 Q Did Ford Motor Credit ever adjust any of those
Page 58 Page 60

1 charges? 1 items on their vehicle, that's strictly up to them. We
2 A Not to my knowledge. 2 just fund the bottom line. We call it discounting or
3 Q Did Ford Motor Credit Company obligate Ms. Albert 3 purchasing the contract.
4 to pay for the documentary fee charge? 4 Q What was the bottom line that Ford Motor Credit
5 A No. 5 Company purchased in this case?
6 Q No? 6 A Once again, the exact dollar amount?
7 A Did we obligate the borrower? No. We were not 7 Q Yes.
8 there at the time of negotiations. 8 A If I could see the account statement or
9 Q After Ford Motor Credit Company purchased this 9 accounting statement, I can give you that exact dollar
10 contract from Friendly Ford, did Ford Motor Credit Company 10 amount. I just don't remember it off the top of my
11 obligate Ms. Albert to pay the charge of $415.72 for the 11 head.
12 documentary fee? 12 Q Is it your testimony today that in looking at the
13 MS. WALKER-PROBST: Objection; vague as to -- 13 sales contract, the total dollar amount that Ms. Albert
14 JUDGE CHOATE: Overruled 14 owed to Ford Motor Credit Company would not be stated,
15 THE WITNESS: No. The borrower obligated 15 which is marked as Exhibit 2?
16 themselves by executing the contract with the 16 A I'm sorry, say that again.
17 dealership. 17 Q Is it your testimony that when we are looking at
18 BY MS. ALBERT: 18 Exhibit 2, which is the original sales contract, you
19 Q Did Ford Motor Credit Company obligate Ms. Albert 19 cannot determine the amount that Ms. Albert was obligated
20 to pay $498 for a security system after Ford Motor Credit 20 to pay Ford Motor Credit Company from this document alone,
21 Company purchased this contract, which is marked as 21 that you need to see some other document?
22 Exhibit 2? 22 A Correct, the reason being because the customer,
23 A No. 23 Ms. Albert, has made payments, they may be not limited to
24 Q Did Ford Motor Credit Company obligate Ms. Albert 24 late charges and additional charges that affect the
25 to pay for the Lojack system in the amount of $595 after 25 account, on top of which this vehicle did go to auction,
Page 61 Page 63
1 Ford Motor Credit Company repurchased this agreement from 1 so that does offset that balance. There are a multitude
2 Friendly Ford? 2 of things that go into that account. That's why the
3 A No. Once again, we were not there at the time of 3 accounting is so important.
4 negotiation for determining what additional products 4 Q How much was credited for Ms. Albert's trade-in
5 Ms. Albert wanted to purchase at the time of sale. 5 of her Lincoln Continental when she purchased this
6 Q Did Ford Motor Credit Company include the 6 vehicle?
7 documentary fee of $415.72 as part of the total amount 7 A According to this contract, she was given a net
8 owed at the time of repossession in 2015 by Ms. Albert? 8 trade-in allowance of $500.
9 A It would have been all-inclusive, yes. 9 Q What is a net trade-in allowance?
10 Q Did Ford Motor Credit Company also include the 10 A That's what it states on the contract. It says
11 security system in the amount of $495 as a charge 11 net trade-in allowance would be what the vehicle is worth,
12 Ms. Albert was obligated to pay after Ford Motor Credit 12 minus any encumbrances that need to be paid off.
13 Company repossessed her vehicle in 2015? 13 Q So assuming that this vehicle is fully paid off,
14 MS. WALKER-PROBST: Objection; vague. 14 does the $500 represent the full market value?
15 JUDGE CHOATE: I'm sorry? 15 A Yes, ma'am, according to what I'm looking at, and
16 MS. WALKER-PROBST: Vague. 16 Mrs. Albert's negotiations with the dealership, Friendly
17 JUDGE CHOATE: Overruled. 17 Ford.
18 THE WITNESS: Once again, it's all-inclusive. 18 Q Going down further in this document, is there
19 BY MS. ALBERT: 19 any place in this document that notified Ms. Albert that
20 Q What does that mean? 20 she would be required to register the vehicle?
21 A When we purchase a contract, we don't purchase a 21 Your counsel is directing you to a page. What is
22 contract determining whether a borrower purchased a 22 the Bates stamp on that page?
23 security system or puts Linex in their truck. That 23 MS. WALKER-PROBST: I'm not, Counsel.
24 doesn't determine whether we are going to purchase a 24 JUDGE CHOATE: You know, the document speaks for
25 contract or not. If a borrower wants to have additional 25 itself.
Page 62 Page 64

1 BY MS. ALBERT: 1 Q Is Ford Motor Credit Company a financial
2 Q Isn't it true that nowhere in that document -- 2 institution?
3 you didn't notify in writing to Ms. Albert that she needed 3 A Yes.
4 to register the vehicle after she purchased it on April 4 Q Are you supervised by the government?
5 29, 2013? 5 A Yes.
6 A That Ford Credit notified? No. 6 MS. WALKER-PROBST: Objection; vague.
7 Q Isn't it true that there's no evidence Friendly 7 JUDGE CHOATE: Overruled.
8 Ford notified Ms. Albert that she needed to register the 8 BY MS. ALBERT:
9 car when she purchased it on April 29, 2013? 9 Q What federal institution actually supervised Ford
10 MS. WALKER-PROBST: Lacks foundation, calls for 10 Motor Credit Company?
11 speculation, vague as to -- 11 A I don't know all of them off the top of my
12 JUDGE CHOATE: Why don't you rephrase the 12 head.
13 question? Are you directing his attention to this 13 Q Is Ford Motor Credit Company also considered a
14 document here? 14 financial company within the State of California?
15 THE WITNESS: Once again, we were not there at 15 MS. WALKER-PROBST: Objection; calls for
16 the time of negotiations. I do not know the conversation 16 speculation.
17 that happened. 17 JUDGE CHOATE: Overruled.
18 JUDGE CHOATE: To that extent, it would call for 18 THE WITNESS: Yes.
19 speculation on the part of the witness. There's very 19 BY MS. ALBERT:
20 little weight given to that, but it might lead to 20 Q Do you know what government agency oversees Ford
21 discoverable material. Conversations that buyer and 21 Motor Credit Company's operations in California?
22 seller have, I think are relevant in this case. 22 A I know we report to several different agencies.
23 MS. WALKER-PROBST: She could ask him what he 23 I don't know their names.
24 knows about those. 24 Q Isn't it true that under the Rees-levering Act,
25 THE WITNESS: I can tell you, looking at this 25 your notice had to be in this document, which we have
Page 65 Page 67
1 document and because there are no charges under titling 1 marked at Exhibit 2?
2 and registration, it is customary for dealerships to have 2 MS. WALKER-PROBST: Objection; calls for legal
3 that discussion with the customer, if they are crossing 3 conclusion.
4 state lines. Okay? Since there are no charges here, I 4 JUDGE CHOATE: Sustained.
5 can only assume -- 5 BY MS. ALBERT:
6 JUDGE CHOATE: Where are you pointing at? 6 Q Isn't it true that nowhere in this sales
7 THE WITNESS: I am pointing to Itemization of 7 agreement does it state that Ms. Albert was required to
8 Finance, Section 3, Line A and B, all the way down to C. 8 register her car in California?
9 JUDGE CHOATE: I see it. 9 JUDGE CHOATE: Once again, the document speaks
10 THE WITNESS: The other thing, there was a charge 10 for itself. You can ask the witness of his knowledge, but
11 for a driveway permit. So I can only make an assumption 11 to say "nowhere in this agreement," the agreement is right
12 on what the discussion was between you, Ms. Albert, and 12 here. It's either in there or it isn't
13 the dealership. 13 BY MS. ALBERT:
14 BY MS. ALBERT: 14 Q Isn't it true Ford Motor Credit Company has
15 Q Was Ford Motor Credit Company required to comply 15 nothing to show that Ms. Albert was notified she was
16 with the Rees-Levering Act? 16 responsible for registering her car in California?
17 MS. WALKER-PROBST: Objection, calls for legal 17 MS. WALKER-PROBST: Objection; vague.
18 conclusion. 18 JUDGE CHOATE: Overruled.
19 JUDGE CHOATE: Sustained. 19 THE WITNESS: Documents that I reviewed that we
20 BY MS. ALBERT: 20 received from the dealership did not indicate who was
21 Q Did you receive any training with regard to 21 responsible at the time for the registration of the
22 compliance with the Rees-levering Act? 22 vehicle. We did have conversations with the dealership,
23 A No. 23 with you as the customer and also the dealership, and
24 Q No? 24 that's where we later found out both sides of the story.
25 A No. 25 ///
Page 66 Page 68

2 Q Isn't it true there's also nothing that shows 2 Q Did Ms. Albert put $6,000 cash down payment
3 Ms. Albert could be sued in Nevada if her car was not 3 toward the purchase of the vehicle from Friendly Ford on
4 registered by March 1, 2014, correct? 4 April 29, 2013?
5 MS. WALKER-PROBST: Calls for legal conclusion. 5 A Yes, according to page FMCC 000181, section 7,
6 The document speaks for itself. 6 line B.
7 JUDGE CHOATE: Overruled. 7 Q Did Ford Motor Credit Company then agree to
8 THE WITNESS: There is no way we would have 8 finance the remainder of the purchase price of this
9 knowledge of that. 9 vehicle that Ms. Albert purchased on April 29, 2013, from
10 BY MS. ALBERT: 10 Friendly Ford?
11 Q I'm saying that there's no notice, correct? You 11 A Yes.
12 couldn't find anything that gave Ms. Albert notice when 12 Q When did Ford Motor Credit Company agree to
13 she purchased her vehicle that she would be sued in Nevada 13 finance the remaining of the purchase price of this
14 if her car wasn't registered by March 1, 2014; is that 14 vehicle?
15 correct? 15 A I don't know the exact date, but it would be on
16 A That's correct. 16 or about the time of the contract itself.
17 Q And Ford Motor Credit Company doesn't have any 17 Q Do you know what the material terms of the sales
18 evidence to show that Ms. Albert was notified when she 18 contract was between Ms. Albert and Friendly Ford?
19 purchased her vehicle April 29, 2013, from Friendly Ford 19 MS. WALKER-PROBST: Objection; vague as to
20 that she could be sued for a charge-back to Friendly Ford 20 "material terms."
21 in Nevada by Ford Motor Credit Company, correct? 21 JUDGE CHOATE: Overruled.
22 MS. WALKER-PROBST: Could you repeat the 22 MS. WALKER-PROBST: Calls for legal conclusion.
23 question? 23 JUDGE CHOATE: I can barely hear you.
24 (The record was read by the court reporter) 24 MS. WALKER-PROBST: Calls for legal conclusion.
25 MS. WALKER-PROBST: Vague as to "any evidence," 25 JUDGE CHOATE: Overruled.
Page 69 Page 71
1 calls for legal conclusion. 1 THE WITNESS: I don't know what you mean by
2 JUDGE CHOATE: Overruled. If you can answer 2 "material terms."
3 that, go ahead. 3 BY MS. ALBERT:
4 MR. BERKLEY: Objection, as to clarification as 4 Q What were the basic terms to the sales contract
5 to which entity we are referencing on the back-end of that 5 between Ms. Albert and Friendly Ford?
6 question. 6 A And you are talking about your payment schedule?
7 JUDGE CHOATE: This is Ford Motor Credit 7 It would be 72 payments at $746.99 per month beginning on
8 Company. 8 June 13, 2013.
9 THE WITNESS: There's nothing in this document 9 Q Did Ford Motor Credit Company have perfected
10 stating that you would be sued. 10 title on April 29, 2013?
12 Q Isn't it true that there is no evidence or 12 Q Did Ford Motor Credit Company have perfected
13 anything that you could find showing that Ms. Albert was 13 title on May 29, 2013?
14 given notice when she purchased her vehicle from Friendly 14 A No.
15 Ford on April 29, 2013, that Ford Motor Credit Company 15 Q Did Ford Motor Credit Company have perfected
16 could obtain a deficiency judgement, correct, if she did 16 title on June 29 2013?
17 not register her vehicle? 17 A No.
18 MS. WALKER-PROBST: Objection; assumes facts, 18 Q Did Ford Motor Credit Company have perfected
19 that the deficiency judgment related to the lack of 19 title on July 29, 2013?
20 registration. 20 A No.
21 JUDGE CHOATE: Do you know? Was she ever so 21 Q Did Ford Motor Credit Company have perfected
22 advised? 22 title on August 29, 2013?
23 THE WITNESS: I don't know if you were advised of 23 A I would have to go back and look at the notes on
24 that or not. 24 when the perfected title was received. I do know it was
25 /// 25 not received within the first three months.
Page 70 Page 72

1 Q Did Ford Motor Credit Company receive a payment 1 A Ford Motor Credit Company.
2 from Ms. Albert by June 13, 2013? 2 Q Who is the owner?
3 A I don't remember the exact dates of the payments. 3 A Sheridan Lenore Luann Albert.
4 If you want to show me the accounting notes, I can tell 4 Q Do you know why the title is written as Sheridan
5 you. I'm assuming -- right now, I'm assuming yes. 5 Lenore Luann Albert?
6 MS. WALKER-PROBST: Don't assume. 6 A I do not.
7 BY MS. ALBERT: 7 Q Do you know who created this certificate of
8 Q Did Ford Motor Credit Company demand that Ms. 8 title?
9 Albert make her monthly payment per the contract, 9 A Department of Motor Vehicles for the State of
10 including the first payment of June 13, 2013? 10 Nevada.
11 A Yes, we expected payment. 11 Q I knew as soon as I said it, it was going to be
12 Q Did Ford Motor Credit Company, LLC, demand 12 that.
13 payment from Ms. Albert per the contract before title was 13 What I mean is, do you know who gave the State of
14 perfected? 14 Nevada the paperwork in order for the State of Nevada to
15 A Yes. 15 create the certificate of title which was then issued on
16 MS. ALBERT: I want go to what's Bates stamped as 16 February 13, 2014, which we have now marked as Exhibit 3
17 Ford Motor Credit Company 61. I will mark this as Exhibit 17 in this case?
18 3. 18 A Yes, it was Friendly Ford.
19 (Exhibit 3 was marked for identification and it 19 Q When the certificate of title was issued by the
20 is attached hereto) 20 State of Nevada on February 13, 2014, did Ford Credit know
21 BY MS. ALBERT: 21 that there was no certificate of title in this transaction
22 Q Have you seen this document before? 22 prior to this time?
23 A Yes, ma'am. 23 A Yes, we were aware of it.
24 Q Do you know what this is? 24 Q When did Ford Motor Credit Company learn that
25 A It's a Certificate of Title issued by the State 25 Friendly Ford had given papers to the State of Nevada to
Page 73 Page 75
1 of Nevada on the vehicle. 1 title the vehicle?

2 Q I represent to you that we have propounded 2 A I would have to look at our customer history
3 request for production of documents asking for title for 3 notes to give you the exact date.
4 every single year and separately for every single year 4 Q I'm going to hand you what is marked as FMCC 20
5 between 2013 and 2015, and as far as our search goes, this 5 to 34, and tell me if this is what you consider to be your
6 was the only certificate of title we could find. 6 customer history notes.
7 You said that you have prepared by looking at the 7 A There is another complete set that gives
8 documents for this deposition today. Other than this 8 additional information.
9 document, which is Bates FMCC 0061, which we have now 9 Q Okay. I'll find the other set then. Hand those
10 marked as Exhibit 3 to your deposition, are you aware of 10 back.
11 any other title? 11 Can you tell us, since we are on this Bates stamp
12 A No. 12 series which says "Contract History," FMCC 20 to 34, why
13 Q Can you explain why we only see half a page of 13 this history isn't as complete as the other ones that you
14 the certificate of title? 14 are referring to?
15 A I cannot. 15 A Yes, ma'am. In our system, as we correspond with
16 Q Do you know what is supposed to be on the 16 not only the customer, but anybody else, you know,
17 right-hand side of the page? 17 anything regarding the account, it all gets captured or
18 A No. 18 notated in our customer history notes. Some of those are
19 Q There is a date where it says "Date issued." Do 19 marked for permanent. Those items never come off. They
20 you see that on the top left-hand side? 20 are always on the customer history notes. Some of the
21 A Yes, ma'am. 21 comments are not notated as permanent, so depending upon
22 Q For the record, what was the date issued for this 22 which report is run at the conclusion, they will either
23 certificate of title? 23 include those, adjust the permanent notes, or it will not
24 A February 13, 2014. 24 include those permanent notes. So we have different ways
25 Q Who is the lienholder? 25 that we can produce these customer history notes. So for
Page 74 Page 76

1 full disclosure, we did provide the one that includes all 1 dealer.
2 notations on the account. 2 Q Prior to that entry, after that entry on February
3 Q And that's what was turned over about a day or 3 21, 2014, do you see, it's right above --
4 two ago, correct? 4 A Yes.
5 A I don't know when it was turned over to you. 5 Q It says "unperfected title." Do you see that?
6 MR. BERKLEY: That isn't correct, I'll just 6 A Yes, I see it.
7 interject. It was a couple of weeks ago. 7 Q What does that mean when Ford Motor Credit
8 MS. ALBERT: I received some on March 31. 8 Company puts an entry onto this log which we have marked
9 JUDGE CHOATE: Let's get back to the witness 9 as Exhibit 5, using the phrase "unperfected title"?
10 here. Go ahead. 10 A That's an automated -- that is an entry stating
11 BY MS. ALBERT: 11 that we had not received the title and that we were
12 Q I am going to show you what is Bates stamped as 12 still -- even though it was indicated, we emailed Charlene
13 133 and see if these are the notes that you are talking 13 with Friendly Ford for status, to find out where the title
14 about. I'm handing you now what is Bates stamped 133 to 14 was.
15 139. Are those the notes? 15 Q If you go to the very last page --
16 A No. This the closure of the account itself. 16 A Page 120?
17 Q I'm going to hand you what has been Bates stamped 17 Q Yes.
18 106 to 120. Are these the notes? 18 A Okay.
19 A Yes, we can use these notes. I'm sorry. You 19 Q Do you see the very first entry?
20 wanted to know when we notated the account for a perfected 20 A Yes.
21 title? 21 Q Was that an entry made by Ford Motor Credit
22 Q When did you first learn that Friendly Ford had 22 Company?
23 sent the documents to Nevada to perfect the title? 23 A It was an entry made by our automated system.
24 A That would be on January 3, 2014. 24 Q Is that automated system controlled by Ford Motor
25 Q What Bates stamp page are you looking at? 25 Credit Company?
Page 77 Page 79
1 A I am looking at FMCC 000119. 1 A Yes.

2 MS. ALBERT: Before we go any further, I would 2 Q And it's dated August 2, 2013, correct?
3 like to mark as our next exhibit in order. I think it is 3 A Correct.
4 5. 4 Q Could you read what the line entry says?
5 (Exhibits 4 and 5 were marked for identification 5 A "Dealer letter sent by title vendor requesting
6 and they are attached hereto) 6 perfect title."
7 BY MS. ALBERT: 7 Q What does that entry mean?
8 Q What informed you on Bates stamp page 119 in 8 A That entry is, once again, an automated entry
9 Exhibit 5 that gives you reason to believe Ford Motor 9 within our system. If the perfected title has not been
10 Credit Company knew on January 3, 2014, Friendly Ford was 10 keyed in, then we start automatically notifying the dealer
11 sending papers off to the State of Nevada to title the 11 so they can start follow-up, because that is their
12 vehicle? 12 agreement between the dealer and ourselves, that they have
13 A Because the customer service rep received a call, 13 to perfect title.
14 and I'll read this, "Received call from dealer, Charlene, 14 Q If the dealer doesn't perfect title, what is Ford
15 at originating dealer, caller states California DMV has 15 Motor Credit Company's remedy?
16 contacted the customer to go in, but she never did. 16 A Our remedy is to have them purchase the contract
17 Customer must submit a smog certificate and VIN 17 back.
18 verification. California rejected the title request and 18 Q Did Ford Motor Credit Company demand that
19 sent paperwork back to the dealer. The dealer will now 19 Friendly Ford purchase the contract back on August 2,
20 title the vehicle in Nevada." 20 2013?
21 Q Who is Charlene? 21 A Not to my knowledge.
22 A Employee for Friendly Ford. 22 Q Why not?
23 Q Why did Ford Motor Credit Company make a notation 23 A Because that's why we are notifying them that
24 with regard to title on January 3, 2014? 24 they need to follow up and perfect the title, otherwise it
25 A Because we received a phone call from the 25 will eventually lead to a buy-back.
Page 78 Page 80

1 Q Does Friendly Ford have a policy or procedure as 1 people that follow up, because part of the assignment
2 to how long they will wait for a dealer to perfect a title 2 agreement is for the dealership to perfect a title. If a
3 before they force the dealer to purchase back the vehicle 3 perfected title is not received, we have people who follow
4 or the contract? 4 up with the dealership to make sure that that's done. If
5 A I don't know that off the top of my head. I'd 5 it's not done, depending upon -- they are then obligated
6 have to peruse that specific policy and procedure, if 6 to purchase that contract back.
7 there's an exact time frame or not. 7 BY MS. ALBERT:
8 Q Was that policy and procedure produced? 8 Q In August 2013, when Ford Motor Credit Company
9 A I believe so, yes. 9 was notified that the system automatically generated an
10 Q Do you know what the title is of that policy and 10 alert that title wasn't perfected yet, did Ford Motor
11 procedure? 11 Credit Company still demand a monthly payment from
12 A Off the top of my head, no, but it would be under 12 Ms. Albert?
13 "Title." 13 A Yes, ma'am.
14 Q The next entry on October 10, 2013, do you see 14 Q And moving forward in time in October 2013, when
15 that? 15 the system generated another alert saying that title was
16 A Yes, ma'am. 16 unperfected, did Ford Motor Credit Company still demand a
17 Q For the record, what does that line entry say on 17 payment from Ms. Albert?
18 Ford Motor Credit Company, contact Ford history dated 18 A Yes, ma'am.
19 October 10, 2013? 19 Q The next entry is November 15, 2013. Do you see
20 A It says "Unperfected title initiated. Determine 20 that?
21 contact party." 21 A Yes, I do.
22 Q What does that mean? 22 Q Is that also a system generated entry?
23 A That is our system notifying our follow-up, our 23 A No.
24 title follow-up department, to start initiating phone 24 Q How do you know?
25 calls with the dealership and to follow up. 25 A I can tell by the -- if you look under the FC,
Page 81 Page 83
1 Q So does Ford Motor Credit Company have a title 1 there's an FCM -- I'm sorry, GMS06. That is actually
2 department? 2 somebody's company number, per se.
3 A We have a title follow-up department, yes. 3 Q Who was assigned FC GMS06 on November 15, 2013?
4 Q Is that the name, official name of the 4 A I would have to look that up.
5 department? 5 Q Do you know who they called?
6 A I don't know the official name of the department. 6 A On that day?
7 I know that -- there's a multitude of different 7 Q Yes.
8 departments. 8 A On November 15?
9 Q Do you know who the supervisor is of that 9 Q Yes.
10 department? 10 A "Called Nevada DMV, no record or VIN number in
11 A No. 11 their system."
12 Q Is it a COM? 12 Q Do you know why Ford Motor Credit Company decided
13 A I don't know the exact hierarchy. 13 to call Nevada DMV?
14 Q Well, I'm questioning, because earlier you were 14 A I can tell you, because it is a Nevada sales
15 adamant about stating that there was literally absolutely 15 contract and it came from a Nevada dealership.
16 nothing that Ford Motor Credit Company had to do with 16 Q Is there a policy and procedure instituted by
17 titling, but now your answer begged the question, because 17 Ford Motor Credit Company on determining who they would
18 what I thought I heard you say was that you said that the 18 call to check up with regard to title?
19 titling department would follow up to determine who the 19 A Yes.
20 contact party was. Is that correct? 20 Q What does that policy and procedure mandate?
21 MS. WALKER-PROBST: Objection; misstates the 21 A To generalize, it is directing the rep to contact
22 testimony, argumentative. 22 the dealership to fulfill their obligation of perfecting
23 JUDGE CHOATE: You can answer that. Is that 23 the title.
24 correct? 24 Q Is there any other phone log that would show
25 THE WITNESS: No, that's not correct. We have 25 other phone calls with regard to perfecting title, other
Page 82 Page 84

1 than what we have marked now as Exhibit 5? 1 JUDGE CHOATE: Overruled.
2 A I believe there is another phone log, but it 2 MS. WALKER-PROBST: You are a PMK, you can answer
3 actually -- all that I can tell you, that phone log is 3 that.
4 also incorporated in this. 4 THE WITNESS: At that time, no, we would not.
5 Q So why didn't Ford Motor Credit Company call the 5 BY MS. ALBERT:
6 borrower, Ms. Albert, and ask about title on November 15, 6 Q Why not?
7 2013? 7 A Because we do not have a perfected title. We
8 A It is within our agreement that the obligation to 8 would have made the dealership purchase the contract
9 title the vehicle or to see that it is successfully done 9 back.
10 is with the dealership. 10 JUDGE CHOATE: May I ask a question? You said
11 Q The next entry refers to a Jane Murphy, TL. Do 11 several times "purchase the contract back." What does it
12 you see that? 12 mean "purchase the contract back," in a practical
13 A I do. 13 statement?
14 Q That's on November 21, 2013. Who is Jane 14 THE WITNESS: What happens is -- because we
15 Murphy? 15 purchased the contract, so we funded the dealership
16 A According to these notes, she's a team lead. 16 approximately $50,000 and change, so if they do not
17 Q A team lead of what? 17 fulfill all the obligations based within that assignment,
18 A Title. 18 then what we'll do, we will take that account and go back
19 Q And why is the title, TL, on it? 19 to the dealership and say, "Here is this contract back,
20 A Because right after the notes, it's right above. 20 here is the account, and you refund us back the $50,000
21 It just means she reviewed the account, so she is 21 and change," because they have not fulfilled their
22 reviewing it to ensure that it's being worked. 22 obligation with us.
23 Q Can you tell what was being worked on at that 23 JUDGE CHOATE: Less any credits for payments that
24 time? 24 were made?
25 A Yes, that we were contacting the dealership. I'm 25 THE WITNESS: Well, I mean, her balance would not
Page 85 Page 87
1 sorry, at that time, we were following up to confirm the 1 fluctuate. I mean, the exact same accounting would be
2 vehicle was titled in Nevada. 2 there, you know, naturally, but I mean, yes, we would make
3 Q Would that comply with the policies and 3 them refund us the amount.
4 procedures of doing a title audit, just calling the 4 JUDGE CHOATE: Thank you.
5 dealership, by Ford Motor Credit Company standards? 5 BY MS. ALBERT:
6 A Overall, yes. 6 Q So was it Ford's custom and practice, as long as
7 Q If we go up to December 4, 2013, there's another 7 the borrower was still paying, even though they did not
8 entry which says "Unperfected title, retail follow-up with 8 have title, they would not force a purchase back by the
9 contact party. Pended until 12/5/13, 6:00, comments, lmrc 9 dealer?
10 for Charlene Wilson w/OD regarding status of title." 10 A No, that's not the case.
11 What does that mean? 11 Q So then why in December 2013, which from April to
12 A Basically it says "left message to call for 12 December is many months, did Ford Motor Credit Company
13 Charlene Wilson with originating dealer regarding status of 13 still hold onto the loan instead of forcing Friendly Ford
14 title," so there was a call logged, but nobody was spoken 14 to purchase it back?
15 to at that time. 15 A Because we were following up with the dealer in
16 Q So on December 4, when title still hadn't been 16 giving them sufficient time in order to perfect the
17 perfected, did Ford Motor Credit Company still demand 17 title.
18 Ms. Albert make a monthly car payment? 18 Q So what is that time frame?
19 A Yes, ma'am. 19 MS. WALKER-PROBST: Objection; asked and
20 Q If Ms. Albert had not made a monthly car payment 20 answered,
21 August, September, October, November, or December 2013, 21 JUDGE CHOATE: Overruled.
22 would Ford Motor Credit Company have instituted a 22 THE WITNESS: Once again, I don't know the exact
23 repossession? 23 time frame. I don't know if there's an exact time frame
24 MS. WALKER-PROBST: Objection; improper, 24 when we say yes, you are going to take this back.
25 incomplete hypothetical. You can answer. 25 ///
Page 86 Page 88

1 BY MS. ALBERT: 1 conversation between Ms. Albert and Ford Motor Credit
2 Q At this point in time, had Ford Motor Credit 2 Company discussing the attempt to register the vehicle on
3 Company instituted any repossession activity or 3 December 31, 2013?
4 collections? 4 A According to these notes, you spoke with the
5 A No. 5 customer service rep, explained status on December 31,
6 Q Up to this point in time, as of December 2013, 6 2013, date stamped 12/24, says she will fax over form,
7 was it impossible for Ford Motor Credit Company to 7 gave her fax number, shortly thereafter, same day, it says
8 institute actual repossession of the vehicle? 8 received, and this is a review, received fax from
9 A Yes, that's correct. 9 customer, not sure if DMV wants title, per fax DMV wants
10 Q On this December 2013 log, can you explain why it 10 the customer's registration to the vehicle, which the
11 doesn't show any contact between Ms. Albert and Ford Motor 11 customer should carry in his vehicle, left message for
12 Credit Company until December 31, 2013? 12 customer to call back, will not be in on January 1,
13 A If there had been any contact with Ms. Albert, 13 Extension 51369, placing fax in follow-up January 2.
14 yourself, with any customer service rep, it should have 14 Q So do you show anything in your system that Ford
15 been notated. 15 Motor Credit Company did anything with the documents that
16 Q Now, the first notation on here shows December 16 Ms. Albert faxed Ford Motor Credit Company on 12/31/2013,
17 31, 2013, at 12:21. Do you see that? 17 other than placing it in a follow-up bin?
18 A Yes, ma'am. 18 A No, it doesn't show.
19 Q Do you know if 12:21 is Eastern time, Pacific 19 Q Going back to our exhibit, which is Bates
20 time, or somewhere in between? 20 stamped 61, that half a title page?
21 A I do not. I can find the answer for you. 21 A Oh, yes.
22 Q And it says the employee is FCKXC11. Do you know 22 Q This is dated February 13, 2014, the certificate
23 who that is? 23 of title with Nevada, correct?
24 A No, I do not. 24 A Yes.
25 Q Did Ford Motor Credit Company record that phone 25 Q On January 3, 2014, flipping back to your Exhibit
Page 89 Page 91
1 conversation? 1 5, it states that there's a discrepant title.

2 A I don't know. 2 A January 3?
3 Q The notations for December 31, 2013, states "CS 3 Q I mean, March 3, 2014.
4 updated mailing address, previous buyer, act, bill info 4 MS. WALKER-PROBST: Which time stamp are you
5 14272 Hoover Street, 69, Westminster 92683, USA." 5 looking at?
6 Do you see that? 6 MS. ALBERT: All of them say it.
7 A I do. 7 THE WITNESS: I could tell you the very first
8 Q What does that mean? 8 one, which is date stamped. You're talking about the
9 A Customer updated mailing address, previous 9 first one date stamped 1932?
10 buyer/lessee account billing info, which is the 10 MS. ALBERT: Yes.
11 information they are taking out, 14272 Hoover Street, 69, 11 THE WITNESS: That is an automatic and
12 Westminster, California, 92683. 12 automatically saying that discrepant or title has been
13 Q And then the call switches over in a minute. Do 13 received and that just automatically puts that in the
14 you see that at 12:22? 14 account note. The very next one, discrepant title
15 A Yes, sir. 15 initiated, is automatic. Somebody has received the title
16 Q It goes over to the -- I'm assuming the debt 16 and they are saying basically, they are hitting a button
17 manager is the next employee? 17 real fast and saying, you know what, we have received the
18 A No. That's the same representative changing 18 title, and that same system is automatically saying this
19 something you requested with the debt manager, which is 19 title needs to be reviewed, you know, for accuracy, and on
20 indicating to anybody else going forward, and it states 20 March 4, the title was reviewed by a person and she moved
21 "Customer prefers contact on job," so what that customer 21 it to archives, so she accepted the title and archived
22 rep is doing is taking whatever you have indicated to them 22 it.
23 and putting that in our system, so everybody knows going 23 BY MS. ALBERT:
24 forward. 24 Q And then above that, what does it say about
25 Q Where in these notes does it show a phone 25 correct buyer?
Page 90 Page 92

1 A She is notating that the buyer's information and 1 a charge-back of approximately $5,000?
2 lienholder's information is correct. 2 A Never.
3 Q So now if we go forward in time to March 14, 3 Q Did Ford Credit Company itself require Friendly
4 2015. 4 Ford to pay a charge-back of $5,000 for failure to have
5 A Okay. 5 the car registered?
6 Q Do you see the entry at 9:09? I don't know if 6 A Ford Motor Company did.
7 it's p.m. or a.m. 7 Q Ford Motor Company. I thought we had stated at
8 A Yes, I do. 8 the beginning that Ford Motor Company and Ford Credit were
9 Q It says title perfected 3/4/15. Can you explain 9 the same?
10 that? 10 MS. WALKER-PROBST: No, Ford Credit. Ford Motor
11 A Oh, that means they utilized a system called 11 Credit Company and Ford Credit are the same. Ford Motor
12 E-Atlas, and pulled up that to confirm that the title was 12 is the manufacturer, not a party to this action.
13 perfected and any additional information on there, and 13 BY MS. ALBERT:
14 then they notated it in there, which would have been -- 14 Q So do you know why Ford Motor Company required
15 E-Atlas indicated that the title is perfected and the 15 Friendly Ford to pay $5,000 as a charge-back because
16 customer information, Lenore Albert, additional 16 Ms. Albert's car was not registered?
17 information 7755 Center Avenue, number 1100, Huntington 17 A I am aware of, yes, I am aware of it.
18 92647. 18 Q Why?
19 Q Well, where is that title? Because the title we 19 A Because when you purchased the vehicle, one of
20 are looking at on Page 61 says Sheridan Lenore Luanne 20 the incentives you utilized was an extremely low rate that
21 Albert in Westminster, California. 21 was being offered by Ford Motor Company, and in order for
22 A Like I said, that particular system -- it's a 22 the dealership to claim that incentive to utilize that low
23 system that pulls in a lot of information from different 23 interest rate, they had to show proof of sale of the
24 sources. It's a collection tool. 24 vehicle. If that proof of sale is not fulfilled within a
25 Q What is the significance of using the date of 25 certain time period, they are charged back on what's
Page 93 Page 95
1 March 4, 2015? 1 called their Vincent statement.

2 A I do not know. 2 The exact parameters and the exact time frames
3 Q Going back to our document that's Bate stamped 3 of when they received that charge-back, I don't know, but
4 61, Certificate of Title? 4 I can tell you -- normally, we don't have Ford Credit, we
5 A Yes. 5 don't have anything, we don't have anything to do in
6 Q To your knowledge, is this the title that was 6 regard to those incentives that are being claimed.
7 then transferred over at the private auction before the 7 Q So you are not allowed to charge your own
8 other Ford dealerships, after Ford Motor Credit Company 8 interest rate?
9 repossessed the car? 9 A Well, I don't understand that question.
10 A Yes. 10 Q You just stated that the reason why Friendly Ford
11 Q Did you receive a copy of this certificate of 11 was charged back $5,000 was because Ms. Albert received a
12 title? 12 low interest rate on the vehicle?
13 A Yes. 13 A Right.
14 Q When? 14 Q And you are also claiming Ford Motor Credit
15 A I thought we just went through this, title 15 Company and Ford Credit are separate from Ford Motor
16 received, March 3, 2014. 16 Company, correct? My question is, with those two things
17 Q After Ford Motor Credit Company received the 17 being true, which you have already testified to under
18 title, did they inform Ms. Albert that they now had 18 oath, then what you are telling me is that you, the
19 perfected title where she could register the vehicle? 19 finance company, Ford Credit, has no control over your
20 A Not to my knowledge. 20 interest rate on the loans that you give. Is that
21 Q Before March 3, 2014, had Ford Credit already 21 correct?
22 required Friendly Ford to pay them approximately $5,000 as 22 MS. WALKER-PROBST: Objection, argumentative.
23 a charge-back because the car was not registered? 23 You can answer.
24 A No. 24 THE WITNESS: No. That is not correct. What
25 Q When did Ford Credit require Friendly Ford to pay 25 they are doing is they are subsidizing -- we have an
Page 94 Page 96

1 interest rate, we have a set interest rate. They are 1 interest rates they are going to buy down on which
2 actually subsidizing -- 2 vehicles in which markets, whether it be locally or
3 MS. WALKER-PROBST: It would help to not use 3 nationally. We do not penalize the customer. We penalize
4 pronouns. 4 the dealership. In regard to our agreements, it's the
5 THE WITNESS: They are buying down the rate and 5 dealership's responsibilities in order to ensure that they
6 because Friendly Ford did not fulfill the requirements 6 fulfill all agreements with us in regards to providing
7 with the motor company in order to get that rate, they 7 correct information, and in this case perfecting a
8 were charged back that difference. 8 perfected title.
10 Q Did Ford Motor Company also require Ford Credit 10 Q When Ms. Albert purchased the vehicle on April
11 to make a payment, because the title was not perfected and 11 29, 2013, was it Ford Motor Credit Company that determined
12 the car wasn't registered? 12 she was going to get this low interest rate or was it Ford
13 A No. 13 Motor Company?
14 Q Why not? 14 A Ford Credit approved the agreement and the terms
15 A I don't understand what you are asking. 15 that were being presented to us. What programs or credits
16 Q First, I might be making the wrong assumption 16 that are being utilized to get to those agreements or
17 here. Does Ford Motor Credit Company have its own 17 terms, that has no bearing on whether you are approved or
18 autonomy in entering into financial arrangements? 18 not.
19 MS. WALKER-PROBST: Overbroad, vague. 19 Q So what was the interest rate that Ford Credit
20 MS. ALBERT: I'll rephrase it. 20 approved on April 29, 2013, in this case?
21 BY MS. ALBERT: 21 A We don't know the -- when a credit application is
22 Q Does Ford Credit have its own ability to 22 originally sent to us, we actually don't know what the
23 determine who it loans money to and at what rate? 23 interest rate is. Basically what we do know, we know the
24 A Yes. 24 collateral, we know the terms. When I say "the terms,"
25 Q And does Ford Motor Credit Company have its own 25 the terms of the loan and the payments, and we also know
Page 97 Page 99
1 ability to determine whether or not it's going to collect 1 either the invoice or wholesale amount to determine the
2 on a vehicle, repossess a vehicle, or have it repurchased 2 advance or how much we are lending, versus the value of
3 back to the dealer? 3 the vehicle, so that's all the basic information that we
4 A As outlined in all agreements, yes. I mean, 4 have, besides the customer's personal information, in
5 that's pretty broad, because you're talking about lending 5 order to make a decision on whether they are approved or
6 agreements with the dealership. I mean, that's all 6 not.
7 inclusive. 7 Q My question is, how do you come out with the
8 Q Does Ford Motor Credit Company have an agreement 8 monthly payment amount of $700-plus -- I believe you said
9 with Ford Motor Company with regard to these low rate 9 $746.99 -- if you don't know the interest rate?
10 incentives? 10 A It is submitted to us from the dealership. We
11 A Yes, they work together. 11 are taking their information to come up with this payment.
12 Q So my question is, under that agreement with Ford 12 You are using an amortization schedule, an APR
13 Motor Company and Ford Credit, if title is not perfected 13 amortization schedule.
14 and the car isn't registered and there's an interest rate 14 Q I feel like we are a little bit chasing our tail
15 that is being subsidized, as you have worded it, 15 here.
16 correct? 16 MS. WALKER-PROBST: I hope we are not chasing it
17 A Yes, ma'am. 17 for too much longer. It's possibly getting close to lunch
18 Q Why is the onus placed then not on the credit 18 time.
19 company, the one that determines the interest rate, rather 19 BY MS. ALBERT:
20 than the dealership? 20 Q Are you stating that Friendly Ford is the entity
21 MS. WALKER-PROBST: Objection; vague and 21 that determined the interest rate?
22 unintelligible. 22 A The interest rate is part of your negotiations
23 JUDGE CHOATE: Overruled. 23 with or a part of your negotiations with Friendly Ford.
24 THE WITNESS: The motor company is the one that 24 You are the one that agreed to the interest rate. We are
25 determines what programs they want to run and which 25 approving a payment. How you get to that payment, it
Page 98 Page 100

1 really doesn't matter to us. 1 strictly between them and the borrower. We do not --
2 Q Do you know what the interest rate was in this 2 that's why we charge-back the dealership, because we will
3 case? 3 not penalize the customer for the dealership not
4 A Yes, ma'am. It's on the sales contract, 1.90. 4 fulfilling their obligation. If the dealership decides to
5 Q So when Ford Credit Company determines that it is 5 go after the customer, that is strictly up to them.
6 to loan money, is it your position that you do not look at 6 Q So then in your notes where you see that
7 the interest rate or at the cost of the vehicle, but you 7 Ms. Albert had informed Ford Credit that the dealership
8 only look at the credit? 8 was going after the customer because Friendly Ford had not
9 A No, that's not what I said. When there's an 9 registered the vehicle, so then Ford Motor Company took
10 original submission, it comes through a system called 10 money from them through the Vincent system, I guess, as
11 Route One. Within that information that we see in order 11 you have called it, for a charge-back of about $5,000 --
12 to approve it, it shows the wholesale or invoice amount of 12 A Yes, ma'am.
13 the vehicle, it shows the amount being lent, it shows the 13 Q Why didn't you, Ford Credit, at that time
14 number of payments, and it shows the payment amount. 14 intervene, so that Ms. Albert could have the car
15 Q Who determines the amount being lent? 15 registered in California?
16 A That's submitted to us from Friendly Ford, and 16 A Once again, that is between you and the
17 then we give them, saying you know what, yes, we are 17 dealership. We are not going to intervene in regard to
18 willing to purchase this contract or no, we are not. They 18 your negotiations with the dealership.
19 have the availability to send that contract and have it 19 Q So do you know why Ford Credit didn't bring in
20 approved at any lending institution. They don't have to 20 Friendly Ford on an indemnity action in this lawsuit?
21 go to Ford Credit. 21 MS. WALKER-PROBST: Objection; calls for a legal
22 Q Was the 1.90 percent already sent to you then by 22 conclusion.
23 Friendly Ford? 23 JUDGE CHOATE: Sustained.
24 A The contract at 1.90, yes, was sent to us. 24 THE WITNESS: I wouldn't know.
25 Q But, I mean before you even made the 25 JUDGE CHOATE: Is it about time to take a break?
Page 101 Page 103
1 determination that you would fund the loan? I'm trying to 1 It is 1:15.
2 get the timing down and who is doing what here. 2 MS. ALBERT: Yes, we can take a break now.
3 A We don't know what the interest rate is until we 3 (Recess from 1:15 p.m. through 2:10 p.m.)
4 receive the contract. 4 JUDGE CHOATE: We are resuming the deposition of
5 Q Okay. 5 Mr. Fernau. Mr. Fernau is present and I am reminding you
6 A So we base our decision upon that basic 6 that you are still under oath and obligated to tell the
7 information I just gave you. If you decide to utilize 7 truth in every particular.
8 that 1.90 percent, then a couple of days later, they will 8 THE WITNESS: Yes, sir.
9 send us the contract, along with a couple of supporting 9 MS. ALBERT: I'm going to hand you what I have
10 documents. We input it in our system. We input this 1.90 10 marked as Exhibit 6, pages Bates stamped FMCC 000189, 190
11 percent. That's when we discover or then we know what the 11 and 197.
12 interest rate is, and it will also cue the motor company 12 (Exhibit 6 was marked for identification and it
13 that not only did Friendly Ford input that they are going 13 is attached hereto)
14 to be utilizing this program, but that they did use this 14 BY MS. ALBERT:
15 particular program for you as a customer. 15 Q Are you familiar with these documents that I have
16 Q So where on our Exhibit 2, I believe it is, the 16 handed you?
17 actual sales contract, where does it notify the borrower 17 A I am familiar with these documents.
18 of any of this that you just described -- that Friendly 18 MS. WALKER-PROBST: I'm sorry, I don't have a
19 Ford is giving this program interest rate and it's not 19 copy. What is the first one?
20 really an interest rate coming from the creditor, and that 20 MS. ALBERT: 189, 190 and 197.
21 it's a program that if Friendly Ford doesn't then perfect 21 MS. WALKER-PROBST: Thank you.
22 title, something that will come back eventually on the 22 BY MS. ALBERT:
23 borrower to have to repay? 23 Q Do each of these documents deal with the security
24 A That is between the dealership and the borrower. 24 system and alarms that were put in the vehicle?
25 If the dealership decides to pursue the borrower, that is 25 A Yes.
Page 102 Page 104

1 Q And the first page of Exhibit 6, could you tell 1 have two boxes checked and initials, so I was not there,
2 us for the record what this is? 2 present when this was executed.
3 A This is Friendly Ford's form describing if the 3 Q Do you know who would have that information?
4 customer wants to keep the alarm or remove the already 4 A Yes, the dealership.
5 installed alarm. 5 Q If you would go to the second page, Bates stamped
6 Q Was this document made at or near the time of the 6 190?
7 event? 7 A Yes.
8 MS. WALKER-PROBST: Objection; lacks foundation, 8 Q Do you know what this document is?
9 calls for speculation. This is a Friendly Ford 9 A I'm familiar with the document.
10 document. 10 Q What is the document?
11 JUDGE CHOATE: Overruled. 11 A At the top it says "LoJack Ancillary Order
12 Do you know? 12 Form.
13 THE WITNESS: I can tell you in the normal course 13 Q How did Ford Motor Credit Company receive this
14 of business -- 14 document?
15 MS. WALKER-PROBST: Your Honor, he's not employed 15 MS. WALKER-PROBST: Same objection.
16 by the dealership. This is the dealership's document. 16 JUDGE CHOATE: Overruled.
17 JUDGE CHOATE: We'll find out about that. You 17 THE WITNESS: I don't know.
18 can cross-examine him on it. 18 BY MS. ALBERT:
19 BY MS. ALBERT: 19 Q Do you know when Ford Motor Credit Company
20 Q Ford Motor Company produced this, the first page, 20 received this document?
21 in this case and Bates stamped it as 189. Do you know how 21 A No.
22 Ford Motor Credit Company obtained this document? 22 Q Do you know who prepared this document?
23 MS. WALKER-PROBST: You said "Ford Motor Company 23 A Who prepared the document?
24 produced." It should be "Ford Motor Credit Company." 24 Q Yes.
25 THE WITNESS: We obtained this from the 25 A The dealership.
Page 105 Page 107
1 dealership. 1 Q How do you know the dealership prepared this

2 BY MS. ALBERT: 2 document?
3 Q When did Ford Credit obtain this document from 3 A Because it's executed with the dealer's
4 the dealership? 4 signature.
5 MS. WALKER-PROBST: Objection; calls for attorney 5 Q What is the customer's name on this document?
6 client privilege. 6 A Lenore Luann Albert Sheridan.
7 THE WITNESS: Do you want to repeat the question 7 Q Does it state whether or not a Lojack was
8 for me? 8 installed in the vehicle?
9 BY MS. ALBERT: 9 A It's an order form to have one installed.
10 Q When did Ford Credit obtain this document from 10 Q Is there a dealer key listed on that page?
11 Friendly Ford? 11 MS. WALKER-PROBST: Objection; the document
12 MS. WALKER-PROBST: If you know independent of 12 speaks for itself.
13 discussions with lawyers. 13 JUDGE CHOATE: If you can answer.
14 JUDGE CHOATE: Without considering anything that 14 THE WITNESS: I see the section. It does say
15 a lawyer may have told you or you may have told a lawyer, 15 "Dealer Key."
16 do you have any independent knowledge as to when Ford 16 BY MS. ALBERT:
17 Credit came in possession of that document? 17 Q Now, if we go to the third page, Bates stamped
18 THE WITNESS: No. 18 FMCC 197, do you know what this document is?
20 Q At the top of the document, how is the customer's 20 Q What is this document?
21 name written? 21 A This is a menu, a presentation menu.
22 A Lenore Luann Albert Sheridan. 22 Q What is a presentation menu?
23 Q Does it state whether or not any alarms were 23 A When a customer goes into the finance department
24 installed in the vehicle? 24 and works with the finance manager, they are at the
25 A I couldn't tell you by this document, because you 25 dealership, sometimes they will utilize these menus in
Page 106 Page 108

1 order to present their products to the customer. It's up 1 when did Ford Motor Credit Company decide to repossess
2 to the customer whether they want to accept or decline 2 Ms. Albert's vehicle?
3 those products. 3 A The request was put in March 16, 2015.
4 Q When you say "menu," is that like a computer 4 Q Do you know why that request was put in?
5 screen or is a piece of paper presented? 5 A Yes.
6 A I cannot testify to what each and every 6 Q Why?
7 dealership does. There's a multitude of different ways 7 A Because we had exhausted all attempts in order to
8 they can present their products. We don't dictate that to 8 work with the customer to collect payments due on the
9 them. We don't dictate how they run their business. 9 account, and the account was delinquent.
10 Q Do you know whether or not this document was 10 Q As of March 16, 2015, had Ford Motor Credit
11 created at or near the time that Ms. Albert purchased the 11 Company given Ms. Albert the title to register the car?
12 vehicle? 12 A No.
13 I would have to go off the date stamp on the -- 13 Q On March 12, there is an entry. It says "T.P.
14 MS. WALKER-PROBST: Lacks foundation. 14 Sabrina dealer," who is Sabrina?
15 THE WITNESS: Do I know for a fact? No. 15 MS. WALKER-PROBST: What is the Bates stamp
16 BY MS. ALBERT: 16 number? I want to make sure he's looking at the page you
17 Q Do you see here where it has "Lojack"? 17 want him to look at.
18 A Yes. 18 MS. ALBERT: He's got it.
19 Q And there's a star next to it? 19 MS. WALKER-PROBST: Is it 114?
20 A Yes. 20 MS. ALBERT: Yes.
21 Q Do you know what the star means? 21 MS. WALKER-PROBST: Thank you.
22 A No. 22 THE WITNESS: Sabrina is a dealer employee.
23 Q Is there; a line drawn? Is there a line drawn on 23 BY MS. ALBERT:
24 the right-hand side of the page of the Lojack theft 24 Q Is that with Friendly Ford?
25 recovery system? 25 A Yes.
Page 109 Page 111
1 A I can see for the Lojack. 1 Q What does it mean by the notation where it says
2 MS. WALKER-PROBST: The document speaks for 2 "No recent contact w/b regarding litigation"?
3 itself. 3 A Exactly what it says, Sabrina was indicating to
4 JUDGE CHOATE: Overruled; answer it, if you can. 4 us in regards to our inquiry, that they had no recent
5 THE WITNESS: No, there's no line. 5 contact with borrower regarding litigation. The contact
6 BY MS. ALBERT: 6 information they had for the borrower is 14272 Hoover
7 Q Is there a line drawn from the right-hand side of 7 Street, Number 69, Westminster, California, 92683.
8 the page to the security system? 8 Q This conversation that happened between Sabrina
9 A For the security system? Yes. 9 at Friendly Ford and Ford Motor Credit Company, who called
10 Q Do you know who drew those lines? 10 who on March 12, 2015?
11 A No. 11 A We initiated the phone call, which is normal
12 Q Do you know when Ford Motor Credit Company came 12 collection efforts.
13 into possession of that document, which is the third page 13 Q If you back up to March 9, 2015, do you see where
14 of our exhibit? 14 it says "inbound dealer"? Does that mean the dealer
15 A The exact date, I do not know. 15 called you on March 9, 2015?
16 Q The top left-hand corner, for the record, who is 16 A Yes, ma'am.
17 the customer? 17 Q If you flip to the next page, it states that
18 A On the menu? 18 there was a phone call from a 3p Monica from phone number
19 Q Yes. 19 702-217-5626. Do you see that?
20 A Lenore Luann Albert Sheridan. 20 A Page 113.
21 Q On any of these three documents did you ever see 21 Q Page 115.
22 my name starting out with Sheridan, as we saw on the title 22 MS. WALKER-PROBST: Ms. Albert, if you could
23 document? 23 identify the Bates number so that we can make sure the
24 A No. 24 witness is looking at the correct document, because there
25 Q Going back to, I believe it was our Exhibit 5, 25 are multiple different sets of notes.
Page 110 Page 112

1 MS. ALBERT: Okay. 1 MS. WALKER-PROBST: Objection; asked and
2 MS. WALKER-PROBST: So what is the Bates number? 2 answered, argumentative.
3 I don't want you to read from the wrong document. Which 3 JUDGE CHOATE: I think it is improper, but we are
4 Bates number are you asking the question about? 4 not in a trier of fact situation. We are trying to get
5 BY MS. ALBERT: 5 some information that might lead to discoverable material.
6 Q Is there more than one entry in this document of 6 MS. WALKER-PROBST: Okay.
7 Monica Jones talking to Ford Motor Credit Company? 7 BY MS. ALBERT:
8 A Actually, I see what you are saying. That is not 8 Q My question is first, how often does it happen
9 us speaking with Monica Jones. That's a continuation of 9 where a third party walks into a dealership with
10 page 114 at the very bottom. 3/19/15, we received a call 10 information on a borrower that is then relayed to Ford
11 from dealer, John with Friendly Ford, and caller ID 11 Motor Credit Company?
12 702-877-6516. Says "Had phone call from third party 12 A Nobody would know that answer.
13 Monica, phone 702-217-5625." He does not know this 13 Q Do you know how many times that happens in a
14 person, nor has he had any recent contact with customer. 14 month?
15 Dealership says this third party called in and 15 A Nobody would know that answer.
16 claimed to have information on borrower if we are looking 16 Q In your experience, has it ever happened up until
17 for the unit. Third party told dealer borrower is an 17 this time?
18 attorney and usually can be found at the courthouse during 18 MS. WALKER-PROBST: Objection; vague as to what,
19 normal business hours. I advised the dealer that I will 19 what has what ever happened?
20 make a note on the account. 20 MS. ALBERT: Answer the question if you can.
21 Q In your experience, since you worked at Ford 21 THE WITNESS: I have received information from a
22 Motor Credit Company since -- 22 dealership on a particular account and inputted that
23 A Ford Credit. 23 information on the account.
24 Q Since 2000, in your experience, how many times 24 BY MS. ALBERT:
25 have you had instances where a third party has went into a 25 Q How many times?
Page 113 Page 115
1 dealership with regards to payments on a car where the 1 A I don't know.

2 dealership then called Ford Credit to see if the credit 2 Q If you go back in time, go back to July 28, 2014,
3 company was looking for the car? 3 which is on your Bates stamp 118?
4 A It is customary for a dealership to share any 4 A Okay.
5 information with us that they may receive, whether it 5 Q What does that notation say at 10:32?
6 be -- however they receive it, if it has something to do 6 A It says this is a team lead/role model review.
7 with the account. 7 They are notating the account, that the account is 13 days
8 Q This conversation took place on March 9, 2015, 8 past due. TL lead team review, buyer is in litigation
9 correct? 9 with dealer over title issue. As long as buyer is making
10 A Yes. 10 payments, there's nothing we have to do. Litigation
11 Q And you have previously testified that you made 11 process with the buyer/dealer is separate issue from Ford
12 the determination to go ahead and start repossession after 12 Motor Credit Company.
13 that point in time, correct? 13 Q Who made that entry?
14 A Yes. 14 A Once again, the TL.
15 Q So now my question is, how often does Ford Motor 15 Q Who is the TL?
16 Credit get a phone call like this? They are not even 16 A That would be the initials STTO3.
17 looking for repossession, but magically appears a third 17 Q Who is STTO3?
18 party who has walked into the dealership where someone 18 A I don't know that person's name off the top of my
19 bought a car, giving their full information, saying we 19 head.
20 know where the borrower is, that dealership then calls you 20 Q Who made the business decision that the
21 as the credit company, before you are even looking to 21 litigation between the buyer and the dealer was a separate
22 repossess the car, and gives you all of her information, 22 issue from FMCC?
23 and it gets down to the detail where there was a 23 A It is part of our -- they are just stating the
24 conversation about what that borrower does for a living 24 part of our agreement that we execute between the
25 and where they can usually be found? 25 dealership and Ford Credit, which has to do with the
Page 114 Page 116

1 assignment and the dealer manual that is the dealership's 1 advised of recurring payments through automated system,
2 responsibility to ensure that the title is perfected. 2 after this payment is made, added number 110 to the
3 Q Did Ford Motor Credit Company authorize the 3 current address." I do not know what VAI stands for.
4 business decision that the litigation process was between 4 "The dealer and DMV won't accept copies, said Friendly
5 the buyer and the dealership, a separate issue from 5 Ford sued her in Vegas, trying to register the unit in
6 FMCC? 6 California, said dealer had the wrong address on paperwork
7 MS. WALKER-PROBST: Objection; assumes facts that 7 and could only find copies and not the originals. Dealer
8 there was any such business decision made. 8 refused to send the DMV the originals, also advised will
9 MS. ALBERT: If any, go ahead. 9 forward for assistance with title," and then we go to 118,
10 THE WITNESS: We don't get involved in regards to 10 "to title the unit, said she is in litigation over title
11 what goes on between the buyer and the dealership. 11 issues with dealer. Said didn't get original paperwork.
12 BY MS. ALBERT: 12 Also said her keys were stolen/lost in Sacramento, not
13 Q Why does it say "Added account message lien 13 able to get copies made due to title issues."
14 perfection issue." 14 So that's all one conversation.
15 A I'm sorry. Where do you see that? 15 Q If you flip back to 119, part of that
16 Q Right above that line. 16 conversation you said, "also advise will forward for
17 A I couldn't tell you why they added that account 17 assistance with title," correct?
18 message. 18 A Yes.
19 Q If you look down on July 16, 2014? 19 Q What did that mean?
20 A Okay. 20 A That they were going to forward your concerns to
21 Q Why is there such a large white space between 21 the title department.
22 "cont" and "also"? Was that a redaction? 22 Q And after this entry, which was made on July 16,
23 A No. 23 2014, do you see anything showing that the person who took
24 Q Why does the sentence start out with a big blank 24 this call from Ms. Albert actually did forward the title
25 and then it says "also her keys were stolen in 25 issues on to the title department of Ford Credit?
Page 117 Page 119
1 Sacramento"? 1 A Yes. If you show that -- on the last entry, same

2 A "Cont" stands for continuation from prior lines. 2 day, there's a "refer to TL for review." On 7/22, there
3 What they are doing, it's a continuous input from one 3 was a note inputted "borrower attorney, in litigation with
4 conversation, so you would have to -- in our system, 4 dealer over title issues." 7/24, "referred to TL, title
5 "cont:," that's automatically stamped. Whatever the 5 issues with dealer and borrower/dealer are in litigation."
6 customer service rep is typing in, their notes come after 6 7/25, "tried to call Ms. Albert, mailbox is full."
7 that. 7 Should I continue?
8 Q Why is there such a large space of almost two 8 Q Yes.
9 inches there that's completely whited out and where we 9 A "On 7/28" that's when the TL went in and stated
10 looked at the last notation, there wasn't any? 10 "13 days past due, TL review, buyer is in litigation with
11 MS. WALKER-PROBST: Objection; assumes facts that 11 dealer over title issues, as long as buyer is making
12 anything was whited out. 12 payments, there's nothing we have to do. The
13 JUDGE CHOATE: I don't know what you are looking 13 litigation process with the buyer/dealership is a separate
14 at, so why don't you rephrase it? 14 issue from FMCC."
15 BY MS. ALBERT: 15 Q So did Ford Motor Credit Company call Ms. Albert
16 Q Look at the white part. Is there a blank part? 16 when they determined that was going to be a separate issue
17 Do you have any concept of how that happened? 17 from Ford Motor Credit Company to inform her that although
18 A No, I'm not a computer programmer. 18 they said that they were going to assist with the title,
19 Q What is your understanding of the phone 19 that they made a determination by July 28, 2014, they were
20 conversation that happened on July 16, 2014? 20 not?
21 A That conversation actually starts on Page 119, 21 MS. WALKER-PROBST: Objection; misstates the
22 and it's -- where it says "talked to buyer, forgot the 22 document.
23 payment, promised reach buyer's law office, talked to 23 JUDGE CHOATE: Overruled.
24 buyer, advised of last payment received on 5/13/2014, 24 THE WITNESS: We stated we -- what is stated is
25 payment of $1508.98 by our automated system to date, 25 they were going to -- the person who received the original
Page 118 Page 120

1 phone call is not part of the title follow-up department, 1 permanent is. Employer, normally they would put your
2 so they assist the customer, they are sending that concern 2 employer behind that and they are also notating that up to
3 to that particular department to find out if we can assist 3 that point that we have been unsuccessful and the customer
4 you as a customer, and we did make a phone call, but the 4 is refusing to pay their payments.
5 mailbox was full. 5 Q What else does that line say? I want the whole
6 BY MS. ALBERT: 6 notation for that entire transaction.
7 Q So did you email Ms. Albert when the mailbox was 7 A It's asking if there's a dealer guarantee, did
8 full? 8 the dealer guarantee the contract, and that answer is no.
9 A Not according to my customer history notes, 9 The last extension, if there's any extensions on the
10 contact history report. 10 account -- there were no extensions.
11 Q Did you send a letter, since the mailbox was 11 Payment history, and it's showing the last
12 full? 12 payment on December 15, 2014, TOE, transfer of equity,
13 MS. WALKER-PROBST: Objection; vague as to what, 13 TOL, SOC, RW basically stands for transfer of equity or
14 vague as to time, vague as to type of letter. 14 rewrite is not applicable, offering comments, and this is
15 THE WITNESS: I'm not aware of a letter that we 15 the comments that were on the approval, this wholesale,
16 have that we would send out. 16 this $54,926, the advance was 92.4 purchase, the purchased
17 BY MS. ALBERT: 17 pop, assistant for probability of payment is 85 percent,
18 Q At any time did Ford Motor Credit Company ever 18 the decision comments are the comments from the person
19 advise Ms. Albert in writing that they were not going to 19 approved this, that they talked to Cheryl prior to
20 assist her with any title issues she was having when she 20 approval, M verified proof of income up front, no auto
21 was attempting to register the vehicle after she purchased 21 experience at this level, would need to see $6,000
22 it on April 29, 2013? 22 customer cash on this unit for stretch call.
23 A At any time? 23 Q What is a stretch call?
24 Q Yes. 24 A A stretch call is considered a call that we are
25 A I would have to go through all the notes. Are 25 willing to do, but it's still outside our comfort zone.
Page 121 Page 123
1 you looking at a specific time period? 1 Q But what is a stretch call?

2 JUDGE CHOATE: You can say I don't know, if 2 A A stretch call is doing the dealership a favor
3 that's your truthful answer. 3 and approving the deal for them.
4 THE WITNESS: Yes. I don't know. 4 Q So this notation is about the dealership?
5 JUDGE CHOATE: That's all right. 5 A This notation includes the comments that we had
6 BY MS. ALBERT: 6 with the dealership at the time of approval.
7 Q There's a notation here on February 26, 2015. Do 7 Q I don't understand what you are trying to tell
8 you see that? It says "letter sent." 8 me? Was the dealership supposed to give you $6,000?
9 MS. WALKER-PROBST: Are you on Bates stamp 116? 9 A No. We would need to receive $6,000 customer
10 MS. ALBERT: Yes. 10 cash.
11 THE WITNESS: Yes. 11 Q Is that what this notation means?
12 BY MS. ALBERT: 12 A Would need to see $6,000 cash. So, basically, in
13 Q What letter was sent and who was it sent to on 13 order for us to purchase that contract, we need to -- we
14 February 26, 2015? 14 are expecting the customer to put $6,000 of their own cash
15 A That letter was sent to Ms. Albert. 15 in order to -- that was one of our stipulations, in order
16 Q What did that letter say? 16 to purchase this contract from Friendly Ford.
17 A I don't know. 17 Q So you are saying on February 26, 2015, Ford
18 Q Did you produce a copy of that letter? 18 Motor Credit had not purchased this contract?
19 A I have never seen that letter. It is an 19 A No. These are the original comments on the
20 automatic within our system, and -- no, I did not produce 20 approval, which was at or around the time of the purchase
21 that letter. 21 of the vehicle back in April of 2013.
22 Q And then there is a notation below that where it 22 Q So you are saying that on February 26, 2015,
23 says "permanent employee refused pay." What does the 23 someone put comments that were actually generated on April
24 notation state or mean? 24 29, 2013, in this section?
25 A Permanent is a permanent comment, that's what 25 A Yes.
Page 122 Page 124

1 Q So let's flip back to April 29, 2013, and my last 1 Q And what Bates stamp number does it end?
2 page is FMCC 120. I don't even see an entry for April 29, 2 A Oh, end, 60.
3 2013. My first entry I'm showing -- 3 Q Does Ford Motor Credit Company have more than one
4 A Not a problem. Once again, I explained it to you 4 account history on my account?
5 before and I'll reiterate this. Those comments came out 5 A I don't know.
6 of a system, out of a different system, and that's the 6 Q In the normal course of business, does Ford Motor
7 Route 1/Pinnacle system, which is what we utilize to 7 Credit Company create more than one account history for
8 approve contracts and purchase them with the dealership. 8 one account?
9 Once they are purchased, that initiates this system, which 9 MS. WALKER-PROBST: Objection; vague.
10 is controlled by what we call work flow. 10 BY MS. ALBERT:
11 Q So was the contract purchased on August 2, 11 Q What is this document, if it not the account
12 2013? 12 history?
13 A No. It just happens to be that was the first 13 A This shows the payments or the account payments.
14 time any comments were made on the account. 14 So is this document called an account history?
15 Q So how can you tell when the contract was 15 MS. WALKER-PROBST: If it's not official --
16 purchased off of this log? Because you said that the 16 MS. ALBERT: Please don't coach him. Let him
17 other system, once the contract is purchased, generates -- 17 answer.
18 A It generates your customer accounts. This is 18 JUDGE CHOATE: Easy. We are starting to get a
19 part -- this is one part of your customer's account. This 19 little late in the day and it's normal that we get a
20 is the print-out of the contract history notes. 20 little short and crabby.
21 Q Is this a complete document? I see on the very 21 THE WITNESS: I don't know at this time. I'd
22 first page it says page 1 and on the last page it says 22 have to look it up.
23 page 15. Is this an incomplete document or -- 23 BY MS. ALBERT:
24 A It's a complete document that we produced in the 24 Q So what does this document show you that's Bates
25 normal course of business. 25 stamped 55 to 60?
Page 125 Page 127
1 Q So then I'm going to ask again, if this contract 1 A It shows the payment history on the account.
2 history report is generated as a result of the date that 2 Q What was the date that the contract was purchased
3 you purchased the contract, why is the first entry August 3 from Friendly Ford to Ford Motor Credit Company?
4 2, 2013, if that was not, in fact, the date that the 4 A It is not reflecting on this report.
5 contract was purchased? 5 Q I'm going to hand you the other document Bates
6 A You would have to look at the account payment 6 stamped 62 to 63. Please tell me if you know what that
7 history report, which would indicate the date that the 7 document is for the record.
8 contract was purchased. 8 A This is the history card that is created after
9 Q Did you produce that? 9 the account is charged off and purged.
10 A Yes. 10 Q What does that mean, when a account is charged
11 Q Do you know what that Bates number is? 11 off and purged?
12 A Off the top of my head, I do not. 12 A Once the service center has exhausted all avenues
13 Q Do you know what the title of that report is? 13 of trying to collect either on the account or deficiency
14 MS. WALKER-PROBST: 55 is the Bates number. 62 14 balance, they will close out that account and, you know,
15 is a better one. 15 create these reports, put them into imaging and then send
16 MS. ALBERT: There should only be one. There is 16 that account to our national recovery center located in
17 one account history, is it 65 or 62? 17 Phoenix, Arizona.
18 MS. WALKER-PROBST: Never mind. Go ahead and 18 Q So this report was not created at or near the
19 find it yourself. What we felt was helpful was to direct 19 time of the purchase, correct?
20 you to those. Go ahead and ask him whatever question you 20 A No.
21 want to. 21 Q Do you have any report that was actually created
22 BY MS. ALBERT: 22 at or near the time of the actual purchase in 2013?
23 Q Here is 62 and here is 55. Which one is the 23 A I don't know.
24 account history? 24 Q According to this document Bates stamped 62 to
25 A It would be starting page 55. 25 63, what date do you believe Ford Motor Credit Company
Page 126 Page 128

1 purchased my loan from Friendly Ford? 1 A 7755 Center Avenue, 1100, Huntington,
2 A I cannot -- according to this, I don't know. 2 California, 92647.
3 Q What date was their repossession date? 3 Q Was this created by Ford Motor Credit Company?
4 A April, according to Exhibit 62, April 6, 2015. 4 A This history card, yes.
5 Q What does it state the loan original amount was 5 Q What is the business phone number, for the
6 on Bates stamp 62? 6 record?
7 A Original proceeds were $50,752.84. 7 MS. WALKER-PROBST: Objection. The document
8 Q Where it says "Plan Code" on the bottom left, 8 speaks for itself.
9 what does "P13C04" mean? 9 THE WITNESS: 714-372-2264.
10 A I don't know. 10 BY MS. ALBERT:
11 Q When it says on the bottom right-hand side, 11 Q Going back to our Exhibit 5, under the decision
12 "Dealer/participant name Valley Apple Ford," do you know 12 comments, it stated "Cheryl prior approval," which was on
13 what that is? 13 page 116 that you had just testified to. What type of
14 A I do not know. 14 prior approval did Cheryl either give or receive?
15 Q Is Valley Apple Ford the dealer that purchased 15 A I don't know that information.
16 the vehicle at the private auction? 16 Q Do you know who Cheryl is?
17 A I would have to look at the auction paperwork to 17 A Cheryl would be a dealer employee.
18 determine that. 18 Q You had said that there was no dealer guarantee.
19 Q Who would know who Valley Apple Ford Inc. is? 19 What is a dealer guarantee?
20 MS. WALKER-PROBST: Objection; lacks foundation, 20 A In some instances, we'll require the dealer to
21 calls for speculation. 21 guarantee a contract if the customer does not make all the
22 MS. ALBERT: I asked "who." "Who" is a 22 payments.
23 foundational -- 23 Q If you go up to another entry, March 2, 2015, at
24 JUDGE CHOATE: Who, if anyone -- 24 11:12 p.m., it shows that Ford Motor Credit Company called
25 THE WITNESS: I would have to review the 25 out to phone number 714-372-2200. Why did Ford Motor
Page 129 Page 131
1 paperwork and I'd be able to find it. 1 Credit Company call that phone number?
2 BY MS. ALBERT: 2 A Because that is a phone number that had popped up
3 Q What paperwork? 3 somewhere, whether it be through collection investigations
4 A All the exhibits. 4 or a prior received phone call, or you know, like through
5 JUDGE CHOATE: Well, let's not do that right now. 5 the collection tools, and so they called that in hopes of
6 Just make a note of that and we'll come back to it and 6 reaching you as the customer.
7 solve it later. 7 Q Do you know the purpose of that phone call?
8 BY MS. ALBERT: 8 A Yes, to speak with you.
9 Q Do you know why the document states on the middle 9 Q About what?
10 left-hand side "Original contract date 4/29/13"? 10 A I'm sure it has to do in regards to working with
11 MS. WALKER-PROBST: I'm sorry. Say that again. 11 you to make the payments on the account.
12 BY MS. ALBERT: 12 Q At that point in time, on March 2, 2015, did Ford
13 Q On the middle right-hand side, it says "Original 13 Motor Credit Company believe that it was entitled to
14 contract date 4/29/13." Do you know what that is? 14 demand a payment from Ms. Albert on that car?
15 A Yeah. 15 A Yes, ma'am.
16 Q What is that? 16 Q Going forward in time, there is an entry on
17 A The original contract date. 17 March 17, 2015, at 11:49. Do you see that?
18 Q Was that the original contract date with Friendly 18 JUDGE CHOATE: Page number?
19 Ford or with Ford Motor Credit? 19 MS. ALBERT: It starts out at 11:49.
20 A That's the original contract date between Ms. 20 BY MS. ALBERT:
21 Albert and Friendly Ford. 21 Q What is this entry?
22 Q And at the top left-hand side of this printout, 22 A This is a phone call with Dedicated Recovery.
23 what is the name of the customer? 23 They indicated to us that the assignment had not been run
24 A Lenore Albert. 24 yet, that they will run it that evening, gave info from
25 Q And what is the address? 25 third party that borrower is usually at the courthouse
Page 130 Page 132

1 during business hours, outside contractor advised two 1 Q Who at Ford Motor Credit Company made that
2 courthouses in Orange County, will run after given and 2 decision?
3 place of employment are run. 3 A I don't know.
4 Q Who is OCR? 4 Q Going back to your notes on March 18, 2015, at
5 A It stands for outside contractor. 5 13:23, on Page 113 --
6 Q Is outside contractor Dedicated? 6 A Okay.
7 A In this instance, yes, ma'am. 7 Q What is this notation?
8 Q And then four minutes later, I'm assuming it's 8 A It is information we received from Dedicated.
9 the same phone conversation, what is that conversation or 9 Q What does the information say?
10 is that not a conversation? 10 A It says the billing address is a multilevel
11 A No, that is not a conversation. That's an 11 business building with parking structures in the back and
12 internet search and within that search, that particular 12 parking all around and no sign of unit. Hoover Street has
13 person located a court document on Google dated February 13 a carport and a few parking spaces, no sign of the unit.
14 24, 2015, borrower representing the plaintiff in Los 14 Outside contractor advises the Los Angeles Superior Court
15 Angeles County Superior Court. 15 is a lot of ground to cover. Unlikely to find unit there.
16 Q And then if we go up to another entry at 13:52 on 16 Advised our contractor of unit's registration in Nevada,
17 the same day, March 17, 2015, what is that entry? 17 not California.
18 A I'm sorry, which one? 18 Q Why was Dedicated advised that the registration
19 Q 13:52. 19 was in Nevada and not California?
20 A That's actually a CarFax report. That's the 20 A Why did we advise --
21 information pulled from CarFax. It's giving the vehicle's 21 Q Yes.
22 information. There is one owner in Nevada, for one year, 22 MS. WALKER-PROBST objection; assumes facts.
23 one month, the CarFax indicated no additional, no issues 23 JUDGE CHOATE: Ask it again.
24 reported, also stated on 93013, the vehicle was serviced 24 BY MS. ALBERT:
25 at Elite Automotive Services in Irvine, California, phone 25 Q Why did Ford Motor Credit Company inform
Page 133 Page 135
1 number 949-454-1000, and on February 13, 2014, title 1 Dedicated that the vehicle was registered in November and
2 issued or renewed with the Nevada DMV in Westminster. 2 not California?
3 Q What does that mean, to have title renewed in 3 A I'm sure it was determined to be pertinent
4 Westminster, California, for a Nevada DMV? 4 information at the time.
5 A I cannot testify to what CarFax reports. 5 Q What made it pertinent?
6 Q Do you know why title was issued in Nevada, 6 A I don't know.
7 instead of having it issued in California, when everything 7 Q Moving on, we are at March 18, 2015, on Page 112.
8 showed I had a California address? 8 I know that you actually have the real recording of this
9 A I have the information that is in the contact 9 phone conversation, but go ahead for the record and read
10 history report and what was indicated to us from both the 10 what you put in your notations of the purported
11 dealership and yourself. 11 conversation at 14:24.
12 Q What do you have? 12 A This is not a conversation.
13 A I show that -- because we had multiple 13 Q What is this?
14 conversations with not only you, but also the dealership, 14 A This is an email.
15 on top of which you sent us a fax. 15 Q Who is the email from?
16 Q And it's your position that because I sent you a 16 A You.
17 fax, I wanted the title registered in Nevada? 17 Q And who is it to?
18 A We did not make that determination to title the 18 A It is to us.
19 vehicle in Nevada. 19 Q Did you receive the email?
20 Q Did you consider that to be a good title when you 20 A Yes. It is notated here.
21 titled in Nevada with a California address? 21 Q Why does it say at the end, "Please do not reply
22 A We accepted the title. 22 to this message via email"?
23 Q Who determined that the title was perfected at 23 A In order to keep your information as private as
24 that point? 24 possible, we do not discuss accounts over email, because
25 A Once we accepted the title. 25 we cannot guarantee who is going to be receiving those on
Page 134 Page 136

1 the other end. We can send you an email saying "Please 1 Q What does B mean.
2 call us," but that's the extent. 2 A Borrower.
3 Q So Ford Motor Credit Company had a very clear 3 Q What does that paragraph read?
4 understanding on March 18, 2015, that Ms. Albert had a 4 A "Borrower advised home and billing address are
5 right to privacy with regard to her account and that 5 the same. Tried to verify home address and borrower
6 information, correct? 6 started yelling about the lawsuit with the dealership.
7 A Oh, absolutely. 7 Refused to provide garaging address. Advised borrower
8 Q Let's go to March 19, 2015, up at 18:32? 8 need make good to stop collection activity. Borrower
9 A Okay. 9 advised will not third party to make payments. Borrower
10 Q What is this notation? Who is DMC? 10 will not stop collection activity until payment posts if
11 A DMC? 11 guaranteed funds not used."`
12 Q What is DMC? After "Debt manager," it says 12 Q Then at 19:12, what are your notes?
13 "DMC." 13 A This is you speaking with the supervisor, "Talk
14 A It's an incoming call. 14 to borrower, upset about dealership, stated sued her for
15 Q What does "LE" stand for? 15 $10,000, then stated that there is now people trying to
16 A LE is a designation for the customer service rep 16 kill her and it is our fault, tried to calm her down,
17 receiving that phone call. 17 advised we need her to pay or we need the unit, asked her
18 Q What does TPY mean? 18 for her garaging address and customer cursed at me and
19 A Oh, so we are going up one more line? 19 hung up."
20 Q That's where I have been. Go ahead. 20 Q And then what happened after that?
21 A Sorry. Third party. 21 A There was a team lead/role model review on the
22 Q So it says "Inbound TP," and then there's a blank 22 account.
23 and it says "other" and then there's a blank. Can you 23 Q What is that?
24 tell me why there's two blanks in there? 24 A The next day.
25 A That's the way our systems works. 25 Q So after Ford Motor Credit Company received
Page 137 Page 139
1 Q Will you read that? 1 information that a borrower was getting some type of death
2 "Third party will be paying $1,500, asked if 2 threat, which Ford Motor Credit Company decided to put
3 borrower was with party to review account. Third party 3 into their system as people trying to kill her, did Ford
4 advised party not available, just stayed away. Did not 4 Motor Credit Company do anything?
5 discuss any account info with third party. No ATP listed 5 MS. WALKER-PROBST: Objection; vague.
6 on account. Strongly recommended to third party that 6 JUDGE CHOATE: Overruled.
7 borrower call to discuss account." 7 THE WITNESS: No.
8 Q So did Ford Motor Credit Company refuse to accept 8 BY MS. ALBERT:
9 the $1,500 from the third party? 9 Q Did Ford Motor Credit Company have any
10 A Yes. 10 information after the July 2014 call that we just
11 Q On March 19, 2015, at 18:32 -- 11 previously went over, which stated the keys were stolen,
12 A This isn't showing that a third party made a 12 so she didn't have access to use the security system, did
13 payment of $1,500. 13 Ford Motor Credit Company have any information between
14 Q Isn't it showing that a third party attempted to 14 March 19, 2015, to July 16, 2014, that that was ever
15 make a payment of $1,500? 15 rectified?
16 A No. 16 A What are the dates again?
17 Q What is it showing? 17 Q July 16, 2014, to March 19, 2015.
18 A It's showing third party advised will be paying 18 A If you had ever received keys?
19 $1,500. 19 Q Right, or received the information?
20 Q Let's move up to same day at 18:43. 20 A No.
21 A Okay. 21 Q You don't recall ever seeing any notation where
22 Q Is that another inbound call? 22 Ford Motor Credit Company learned that Ms. Albert received
23 A Yes. 23 the key code from the dealer?
24 Q What does TTC mean? 24 A No, I do not remember reading that. We don't
25 A Talked to customer. 25 have access to that information.
Page 138 Page 140

1 Q At any time during that phone conversation that 1 out for repossession during that March 19 conversation,
2 occurred on March 19th, 2015, did Ford Motor Credit 2 and we as customer service had advised you that until we
3 Company ever advise Ms. Albert that Monica Jones had 3 receive certified funds or funds, the collection would
4 already contacted them about her? 4 continue. All this is advising is that if this particular
5 A We would not. 5 unit in customer service has exhausted all their tools and
6 Q Why not? 6 if they feel that communication has broken down, then they
7 A It's not the normal course of business. 7 are going to pass that on to the next department.
8 Q Was it Ford Motor Credit Company's belief that 8 BY MS. ALBERT:
9 they owed Monica Jones a right to privacy? 9 Q As of March 19, 2015, Ford Motor Credit had not
10 MS. WALKER-PROBST: Objection; vague. 10 informed Ms. Albert that title had been perfected,
11 JUDGE CHOATE: Overruled. 11 correct?
12 The question was, does Monica Jones in the 12 A I can't tell you one way or another without
13 opinion of the company have a right to privacy? 13 reading through the entire notes.
14 THE WITNESS: We believe that everybody has a 14 Q Have you seen any documents that suggest that
15 right to privacy. 15 Ford Motor Credit Company sent Ms. Albert a copy of the
16 BY MS. ALBERT: 16 title after the car was registered in Nevada?
17 Q Moving on to the next day, March 20, 2015. You 17 A That is not a normal course of business.
18 have a notation here about high balance customer unwilling 18 Q So would you agree that Ford Motor Credit Company
19 to cooperate. Do you see that? 19 never sent Ms. Albert a copy of the title after it was
20 A Yes. 20 registered in Nevada, so she would have noticed that title
21 Q Was that a phone conversation or just a notation 21 was perfected?
22 in the system? 22 A I can say that we did not send you a copy of the
23 A That is a notation by a team lead or a role model 23 title.
24 stating, giving a synopsis of the account at that point in 24 Q Moving on, if you go to Bates stamp 111, the very
25 time. 25 bottom entry is March 20, still on 11/18.
Page 141 Page 143
1 Q Why does it state that they couldn't locate the 1 A Okay.

2 customer or the unit the next day on March 20, 2015, after 2 Q Who made this entry?
3 they had a detailed conversation with Ms. Albert? 3 A Customer service rep.
4 A The team lead or role model is advising the 4 Q And was that a phone conversation?
5 customer service rep that if we are unable to locate our 5 A Yes.
6 customer or locate our unit to let's prep this account 6 Q Who was the phone conversation with?
7 with skip assistance. 7 A Dedicated Recovery.
8 Q What is skip assistance? 8 Q What does it state?
9 A When all normal collection efforts have been 9 A It states the agents ran Hoover address, door
10 exhausted and the customer is either refusing to pay or 10 knock, no answer, unit not seen at home, area search, no
11 doesn't have the ability to pay and is not working with us 11 unit, ran after 6:00 p.m., so business was closed. Asked
12 in regards to our different tools that we have, then we 12 POE today during business hours and to confirm borrower's
13 enlist -- we have what is called a skip account, which are 13 place of employment listed as Suite 1100. Several names
14 a little more seasoned customer service reps. 14 reporting there, ran Hoover address again and contact
15 Q Can you explain why Ford Motor Credit Company 15 neighbors.
16 received a phone call from Bianca stating I have the 16 Q On that same day, about an hour later, do you see
17 $1,500 to pay, and then a few minutes later your notes 17 where you have an entry that says "Okay to offer finder's
18 show that Ford Motor Credit Company is speaking to me, 18 fee of $290"?
19 Lenore Albert, and it ends in a hang-up and Ford Motor 19 A Yes.
20 Credit Company instead of obtaining the payment now is 20 Q And who made that entry?
21 resorting to repossession? 21 A RJLT0.
22 MS. WALKER-PROBST: Objection; vague and 22 Q Who is RJLT0?
23 unintelligible. 23 A I don't know.
24 JUDGE CHOATE: Overruled. 24 Q Who made this entry? What type of person at the
25 THE WITNESS: Actually, the vehicle was already 25 company? If you don't know who it is, what did they do?
Page 142 Page 144

1 A It would be either a senior customer service rep 1 Q At that point in time, Ford Motor Credit Company
2 or a team lead. 2 already knew that Monica Jones was not my neighbor,
3 Q Do you know why all of a sudden magically 3 correct?
4 appearing an hour later we have this notation "Okay to 4 A There was no way we could know who your neighbors
5 offer FF290"? 5 are, exactly.
6 A When we are having troubles, either trying to 6 Q There is a notation on March 25, 2015, at 14:25
7 work with the customer and either getting the payments or 7 p.m. referencing Monica Jones. Do you see that?
8 have them voluntarily bring in the vehicle or create a 8 A Yes.
9 mutual place to pick it up, and we are unable to find it, 9 Q What does it state?
10 we will approve up to, you know -- we will approve 10 A It states a current phone search of phone number
11 X-amount of dollars to offer a finder's fee to assist us 11 702-217-5626 listed to Monica Jones, address 149 Cologne
12 in regards to finding that vehicle. 12 Court, Henderson, Nevada, 89074.
13 Q Will you give that finder's fee to someone who is 13 Q How did you obtain that information?
14 not licensed under our BISA, which is basically an 14 A Through Accurint. It's a collection system that
15 investigation and search agency here in California? 15 we use.
16 JUDGE CHOATE: Why don't you rephrase that 16 Q Did Monica Jones give you permission to run her
17 question? 17 information through Accurint?
19 Q Will you offer the finder's fee to someone who is 19 Q Was she a customer?
20 not a licensed repossession agent or a licensed 20 MS. WALKER-PROBST: Lacks foundation, calls for
21 investigator? 21 speculation.
22 A Yes. 22 MS. ALBERT: I'm asking was --
23 Q Is that Ford Motor Credit Company's custom and 23 JUDGE CHOATE: Overruled.
24 practice, to offer finder's fees to persons who are 24 THE WITNESS: No.
25 neither licensed to repossess cars or is a licensed 25 ///
Page 145 Page 147
1 investigator? 1 BY MS. ALBERT:

2 A It is very customary when everything else has 2 Q Do you have any idea?
3 been exhausted to offer a customer's neighbors or friends 3 A What's the question again?
4 a finder's fee to assist us in gaining our collateral. 4 Q Was she a customer?
5 Q The next day there's an entry on March 25. It 5 A I don't know.
6 says "Left voice mail to Scott to advance $200 finder's 6 Q Was she an employee?
7 fee, approved," correct? 7 A No.
8 A Actually, left voicemail for Scott to advise $200 8 Q Was she a vendor?
9 finder's fee approved. 9 A I don't know.
10 Q And "FF," does mean finder's fee, for the record, 10 Q Did she have any type of contractual relationship
11 correct? 11 with Ford Motor Credit Company when you ran her identity
12 A Yes, ma'am. 12 through the Accurint system on March 25, 2015?
13 Q Who is Scott? 13 A I don't know.
14 A Scott works for Dedicated Recovery. 14 Q If we go about half an hour later on March 25,
15 Q Do you know Scott's last name? 15 2015, where it starts out DMC at 14:52, is that a phone
16 A I do not. 16 call?
17 Q Was someone at that point asking for a finder's 17 A At 14:52?
18 fee? 18 Q Yes.
19 A I don't know. 19 A Yes.
20 Q After that entry, why is there another entry that 20 Q Is that an inbound or outbound phone call?
21 same day at 11:18? 21 A That's an inbound call.
22 A Actually, it's an inbound call. Scott called 22 Q Let's back up to 14:26.
23 from Dedicated, provided the phone number 909-969-4306, 23 A Okay.
24 and he's stating he will offer the finder's fee of $200 to 24 Q Where it says "Called Monica Jones," do you see
25 neighbors. 25 that?
Page 146 Page 148

1 A I do. 1 who is --
2 Q Did Ford Motor Credit Company call Monica Jones 2 JUDGE CHOATE: He just read that.
3 on March 25, 2015, at 14:26? 3 BY MS. ALBERT:
4 A Yes. 4 Q So what did Ford Motor Credit Company do when
5 Q Did they leave a message on her answering machine 5 They received that information from Monica Jones?
6 when they made that call? 6 MS. WALKER-PROBST: If anything.
7 A I cannot tell by the notation. 7 THE WITNESS: We didn't do anything. We just
8 Q What does the notation read? 8 wanted our collateral.
9 A It says "Telephoned non-customer other answering 9 BY MS. ALBERT:
10 machine, called Monica Jones with telephone number 10 Q Did you offer her $300?
11 702-217-5626 due to extended period of no contact with 11 A Yes, as stated.
12 customer." 12 Q Did you warn Ms. Albert after receiving that
13 Q What does "extended period" mean? 13 March 25, 2015, call that you were in contact with Monica
14 A Extended period. 14 Jones?
15 Q But isn't it true less than a week prior you had 15 A No.
16 spoken to myself? 16 Q Did Monica Jones ever represent to Ford Motor
17 A Yes. 17 Credit Company that she had a license to repossess
18 Q So you state now that there's an inbound call at 18 vehicles?
19 14:52, correct? 19 A No.
20 A No. Actually, it starts at 14:53. It's a 20 Q Did Monica Jones ever represent to Ford Motor
21 continuation. 21 Credit Company that she was a licensed investigator?
22 Q Well, 14:52, if I remember, comes before 14:53, 22 A No.
23 right? 23 Q Let's go to the next day, March 26, 2015, at
24 A I understand. 24 11:22.
25 Q Who called Ford Motor Credit Company on March 25, 25 A Okay.
Page 149 Page 151
1 2015, at 14:52? 1 Q It says that Ford Motor Credit Company received

2 A Monica. 2 another phone call from Monica, correct?
3 Q Is that Monica Jones? 3 A Correct.
4 A Yes. 4 Q And what was the substance of that phone
5 Q What was the substance of that conversation? 5 conversation?
6 A "Inbound, other. Monica returned call, she 6 A Monica called in and said "borrower's assistant,
7 doesn't know borrower herself, but borrower is suing 7 Bianca Barrientos (not Alvaros), 1327 Baker Street, Costa
8 people she knows, borrower lives in trailer park, advised 8 Mesa, 92626, lives with her dad, may be parking in back.
9 finder's fee $300. Said borrower is crazy, gets 9 Bianca is terrified of borrower, but she is driving for
10 restraining orders against people she's represented, said 10 borrower. She checked and no court scheduled for either
11 borrower hires criminals to drive her around. She hired 11 today or tomorrow."
12 Bruce Orlando Bosley as a process server, said he's cab 12 Q So now Ford Motor Credit Company has received a
13 driver up on rape charges, said borrower hasn't driven in 13 second fantastic colorful phone call from Monica Jones.
14 a few years. She has men drive her around. Said this 14 At that point in time, did Ford Motor Credit Company warn
15 vehicle doesn't have license plates, still has the 15 Ms. Albert that it had offered Monica Jones $200 to locate
16 Friendly Ford tag. Said Bianca is very close to borrower. 16 her vehicle?
17 She will get borrower's court schedule for the next few 17 A No.
18 days and try to find out who is driving her." 18 Q What did Ford Motor Credit Company do with this
19 Q Now, at this point in time, isn't it true that 19 information, once it received it from Monica Jones?
20 Ford Motor Credit Company was already alerted that the 20 A We provided the given garaging address to
21 borrower, me, Ms. Albert, was receiving threats? 21 Dedicated in hopes of just recovering our collateral.
22 A You had stated that the week prior. 22 Q When you left the first voicemail on March 25th
23 Q Now the following week, isn't it true Ford Motor 23 to Monica Jones, did you advise her that you were trying
24 Credit Company receives a phone call from Monica Jones 24 to repossess the vehicle?
25 stating all kinds of things from Ms. Albert using someone 25 A No.
Page 150 Page 152

1 Q How did Monica Jones know that you were trying to 1 A No.
2 repossess the vehicle? 2 Q Why not?
3 MS. ALBERT: Calls for speculation. 3 A Because we are not going to just arbitrarily
4 JUDGE CHOATE: Sustained. 4 provide that information. There has to be some tie-in
5 BY MS. ALBERT: 5 with the account.
6 Q Did you discuss my information on payments with 6 Q So as long as I know the name of the borrower,
7 Monica Jones? 7 you could give me that information?
8 A No. 8 A If you call in with verifiable pertinent
9 Q After she called in to Ford Motor Credit Company, 9 information and can tell us where the collateral is
10 how were you able to locate the correct account, since she 10 located, we'll work with you.
11 was not the borrower? 11 Q And Ford Motor Credit Company does not require a
12 A We would have pulled your account up by your 12 license in order to have that relationship, correct?
13 name. 13 A No.
14 Q What name did you have on the account? 14 MS. WALKER-PROBST: When you get to a good
15 A Lenore Albert. 15 stopping point, I need to use the ladies' room.
16 Q Were there any other Lenore Alberts that were 16 MS. ALBERT: Okay, we can stop right now.
17 customers? 17 (Recess from 4:01 p.m. through 4:06 p.m.)
18 A I don't know. 18 JUDGE CHOATE: The witness is reminded you are
19 Q Did you keep a recording of these March 2015 19 still under oath. We are going to tighten this up.
20 phone conversations between Ford Credit and Monica 20 BY MS. ALBERT:
21 Jones? 21 Q On March 27, 2015, there's a notation that says
22 A I don't know. 22 Ford Motor Credit Company had received a message from
23 Q Do you know why Monica Jones called back the next 23 Monica Jones where she advised Ford Motor Credit Company
24 day about Ms. Albert's court schedule? 24 that borrower had Bianca call FMCC to try and track FMCC
25 A I don't know. I can't testify to what compels 25 so she could sue FMCC.
Page 153 Page 155
1 Monica to do anything. 1 A Yes, that's what it states.

2 Q Did Ford Motor Credit Company give Monica Jones 2 Q Was there a prior conversation between Monica
3 any indication why they were offering her $300 finder's 3 Jones and Ford Motor Credit Company about a lawsuit?
4 fee? 4 A No.
5 A Yes. We advised her that there's a finder's fee 5 Q What lawsuit was she referring to? Was that the
6 to procure our collateral. 6 Las Vegas litigation?
7 Q Did Ford Motor Credit Company intentionally 7 A The way that I interpret these notes is she is
8 inform Monica Jones that it was going to pay her a 8 alleging that Bianca called us in order to trap us to be
9 finder's fee, because they wanted to collect their 9 able to create some kind of a lawsuit.
10 collateral from Ms. Albert? 10 Q Now, after hearing -- what is TPF on the next
11 A Yes, we did advise her that there was a finder's 11 line? It says "Monica now has contact with a TPF who had
12 fee. 12 worked for B for three weeks helping her."
13 Q Was it Ford Motor Credit Company's custom and 13 A It would be third party.
14 practice to inform third parties when they were attempting 14 Q Is there a difference between TPY and TPF?
15 to collect collateral on other accounts? 15 A Essentially it means third party. Unfortunately,
16 A Yes, it is customary. 16 some of these acronyms that are used by customer service
17 Q So is that considered a public record? 17 reps, it could be either typing very quickly, because as
18 MS. WALKER-PROBST: Objection; vague as to what 18 you can see, we abbreviate quite a bit, you know "B"
19 is considered a public record. 19 stands for borrower, and so on and so forth, so it could
20 BY MS. ALBERT: 20 be a typo. She could mean third party friend, but I was
21 Q Collecting collateral on accounts, for example -- 21 not going to speculate that stands for third party friend.
22 A We have policies and procedures on it. 22 I do know it stands for third party.
23 Q Could I call into Ford Motor Credit Company today 23 Q So after you had received this message on March
24 and ask for all of the accounts in Huntington Beach where 24 27, 2015, did Ford Motor Credit Company call Ms. Albert
25 Ford is attempting to collect collateral on? 25 and warn her that they were speaking with Monica Jones?
Page 154 Page 156

1 A No. 1 MS. WALKER-PROBST: If you can answer it without
2 Q And there's a couple of other entries. Let's 2 talking about what we have talked about.
3 move up to April 1, 2015? 3 THE WITNESS: I cannot.
4 A Okay. 4 JUDGE CHOATE: Let's go off the record so we can
5 Q Is that a phone conversation between Ford Credit 5 discuss this.
6 and Dedicated? 6 (Discussion off the record)
7 A Yes. 7 BY MS. ALBERT:
8 Q And it says he what, advised informant -- 8 Q When there were several people that he informed
9 A "Called Dedicated with telephone number 9 were now assisting, was Ford Motor Credit going to give a
10 909-941-9198, talked to Scott. He advised informant has 10 finder's fee of $300 to each one of those informants?
11 made contact with him directly. He advised there are 11 A No, ma'am.
12 several people now assisting him to locate this. Reminded 12 Q After Ford Motor Credit Company learned from
13 finder's fee of $300 has been offered to informant." 13 Dedicated on April 1. 2015, that there wasn't just one
14 Q Who is the informant? 14 person involved, but now there were several people
15 A I don't know. We don't know. 15 involved, did Ford Motor Credit Company contact Ms. Albert
16 Q Is the informant Monica Jones? 16 and warn her that several people were looking for her
17 A I don't know. 17 car?
18 Q Did you ask Dedicated who the informant is? 18 A No.
19 A No. 19 Q Did Ford Motor Credit Company attempt to
20 Q Why not? 20 determine whether the several people were licensed to
21 A It was not pertinent information to ask at that 21 repossess vehicles?
22 time. 22 A No.
23 Q In preparation for your deposition today, did you 23 Q Did Ford Motor Credit Company determine whether
24 ask Dedicated who the informant is? 24 or not those several people were licensed investigators by
25 A No. 25 the State of California on April 1, 2015?
Page 157 Page 159
1 Q Why not? 1 A No.

2 A In preparation, I have found out who the 2 Q On April 6, 2015, you have almost a page full of
3 informant is. 3 entries on page 108. Do you see that?
4 Q Who is the informant? 4 A I do.
5 MS. WALKER-PROBST: Objection. 5 Q When was the first phone call made on April 6,
6 JUDGE CHOATE: I'll sustain it, unless there's 6 2015?
7 grounds to allow it into evidence. Is this a confidential 7 A The first phone call came in on April 6, 2015,
8 informant? 8 date stamped 14:39, caller ID is 714-217-5626.
9 MS. ALBERT: It's not, but -- 9 Q What was the substance of that conversation?
10 JUDGE CHOATE: Then the name of that witness 10 A Informant called in to advise they were just sent
11 should be told. If you want to divulge it off the record, 11 a picture showing the car is in the parking lot at the
12 I'll let you do that. 12 courthouse on Sixth and Flower. She tried to reach the
13 MS. ALBERT: If you could answer it separate and 13 outside contractor, but couldn't. Advised I will get hold
14 apart from what your lawyers have told you. 14 of them right away.
15 THE WITNESS: I cannot. 15 Q And the outside contractor was located in
16 MS. WALKER-PROBST: It's attorney-client 16 Fontana, correct?
17 privilege. 17 JUDGE CHOATE: If you know.
18 MS. ALBERT: It couldn't be attorney-client 18 THE WITNESS: I don't know.
19 privilege, it's in their notes. The fact that you might 19 BY MS. ALBERT:
20 have -- 20 Q Was the car, in fact, repossessed at Sixth and
21 JUDGE CHOATE: Time-out. Just a second. 21 Flower?
22 Do you know the name of the informant? 22 A I don't know the exact place it was repossessed
23 MS. WALKER-PROBST: If the only way he knows that 23 at.
24 information is from Mr. Berkley or myself -- 24 Q In fact, it was repossessed in the parking lot of
25 JUDGE CHOATE: We don't know that. 25 the courthouse at Central Justice Center, located at 700
Page 158 Page 160

1 Civic Center Drive, Santa Ana, California, correct? 1 Q Did Ford Credit inform Monica Jones when she
2 A I don't know the exact address. 2 called in on April 6, 2015, that they would attempt to
3 Q Do you know why they didn't just simply repossess 3 repossess the car at the courthouse parking lot?
4 the car while Ms. Albert was sitting here working at the 4 A No. We advised that we would provide that
5 law office at 7755 Center Avenue in Huntington Beach? 5 information to the outside contractor, Dedicated Recovery.
6 A Ms. Albert, you had every opportunity to work 6 Q Well, did you tell Monica Jones on April 6, 2015?
7 with us and voluntarily surrender that vehicle without us 7 A In that one conversation or the entire day?
8 having to chase it down. 8 Q The entire day.
9 Q I'm asking you a question. Why didn't you just 9 A She called in, "The informant called in and
10 have the repossession agent pick it up at 7755 Center 10 advised they were just sent a picture showing the car was
11 Avenue in Huntington Beach? 11 in the parking lot at Sixth and Flower, she tried to reach
12 A According to their notes, they did come through 12 the outside contractor, but couldn't, advised I'll get a
13 here. 13 hold of them right away."
14 Q Why didn't you pick up the vehicle at 14272 14 April 6, 2015, time stamp 15:52, "Inbound call,
15 Hoover Street? 15 informant inadvertently let someone else they have helping
16 A They did run that address. 16 know about the finder's fee, advised informant to think
17 Q Did you pay Dedicated $300 so that Dedicated 17 how they want us to handle the finder's fee and let us
18 could pay Monica Jones $300? 18 know tomorrow."
19 A I don't know who Dedicated paid the $300 to. 19 Those are the two conversations we had.
20 Q Did you pay Dedicated $300 for a finder's fee? 20 Q When Ford Motor Credit Company received that
21 A For a finder's fee reimbursement, yes, we did. 21 photo, was that forwarded from Monica Jones to --
22 Q If Monica Jones had assisted you, would you have 22 A We never received a photo.
23 paid Dedicated the $300 finder's fee? 23 Q So, you just heard it from Monica Jones?
24 A If Dedicated Recovery would have shown that they 24 A Correct.
25 had proof that they had paid that finder's fee, an 25 Q When Ford Motor Credit Company received
Page 161 Page 163
1 approved finder's fee to any informant, yes, we would 1 information from Monica Jones that someone, at least one
2 reimburse them. 2 person, had taken a photo of Ms. Albert's car in the
3 Q Was that $300 finder's fee then tacked on to the 3 courthouse parking lot on April 6, 2015, did Ford Motor
4 total owed? 4 Credit Company make any effort to attempt to call Ms.
5 A No. 5 Albert that there were third parties out there, outside of
6 Q So it never went into the auction price? 6 the parking lot taking photos and waiting for her?
7 A No. 7 A No.
8 Q It never went to the invoice price? 8 Q Did Ford Motor Credit Company ever ask Ms. Albert
9 A No. 9 about any details of the people who were sending her
10 Q What was the $600 for that Ford Motor Credit 10 threats?
11 Company paid to Dedicated? 11 A No. Hopefully, she would go to the police.
12 A $300 is the normal repossession fee and then $300 12 MS. ALBERT: I'd like to mark as Exhibit 7 Bates
13 is the reimbursement for the finder's fee. 13 stamped ALB323 through 333.
14 Q Did you include the $600 as part of the charges 14 (Exhibit 7 was marked for identification and it
15 for the auction? 15 is attached hereto)
16 A No. 16 MS. WALKER-PROBST: And that's been produced in
17 Q So when we calculate out your invoice, there 17 this case?
18 won't be any charge at all for the services from Dedicated 18 MS. ALBERT: It's being produced right now.
19 Recovery? 19 MS. WALKER-PROBST: So that's the production that
20 A There will be a $300 charge for the repossession, 20 you are handing over to Mr. Berkley?
21 which is customary and allowable by law. 21 MS. ALBERT: Yes.
22 Q Did Ford Motor Credit Company inform Monica Jones 22 JUDGE CHOATE: Okay. We need to have a meeting
23 that they would try to repossess the car at the courthouse 23 here before everybody goes home.
24 parking lot on April 6, 2015? 24 It's fairly characterized as a police report?
25 A Did Ford -- I'm sorry. Say that again. 25 MS. ALBERT: Yes, the police report.
Page 162 Page 164

2 Q So going back to 2014 when Ford Motor Credit 2 Q Isn't it true Ms. Albert notified Ford Motor
3 Company was notified by Ms. Albert that her keys were 3 Credit that she had a restraining order against George
4 stolen. The first report is showing one of April 2014 4 Olivo?
5 where she made a report that her keys were stolen, 5 A Specifically on what date was that?
6 correct? 6 Q Didn't she advise Ford Credit in July of 2014
7 JUDGE CHOATE: Are these car keys? Everybody has 7 that she had received, the first time, that she had
8 been saying keys, but these are the car keys? 8 received a restraining order against George Olivo, who
9 MS. ALBERT: Yes. 9 attempted to assault her?
10 THE WITNESS: Are you talking about Exhibit 5? 10 MS. WALKER-PROBST: Do you have a Bates number?
11 MS. ALBERT: The exhibit that is right in front 11 MS. ALBERT: He's looking at it right now. It's
12 of you. 12 our next exhibit, Exhibit 8.
13 MS. WALKER-PROBST: She's asking him to interpret 13 THE WITNESS: I can't make that determination off
14 a police report. Lacks foundation, calls for speculation, 14 this.
15 document speaks for itself. 15 JUDGE CHOATE: It's all predicated on hearsay.
16 JUDGE CHOATE: Overruled. Ask your next 16 THE WITNESS: I mean, I can look in our notes.
17 question. 17 JUDGE CHOATE: It doesn't mean it's inadmissible
18 BY MS. ALBERT: 18 for this procedure.
19 Q Now that Ford Credit has been handed the actual 19 Let's see if we can tighten this up a little
20 police report, is there a policy and procedure that Ford 20 bit. Let's get it done.
21 Credit follows in order to ensure that their borrower, if 21 BY MS. ALBERT:
22 their keys are stolen, can have them replaced? 22 Q If Ford Credit knew that there was someone who
23 A What do you mean "follow"? 23 had a history of violence that was threatening Ms. Albert,
24 Q Does Ford Motor Credit have a custom and practice 24 did Ford Motor Credit Company have a custom and practice
25 when one of their borrowers has their keys stolen to be 25 or policy and procedure in place to ensure that
Page 165 Page 167
1 sure that they get replaced? 1 information would not be submitted by Ford Motor Credit
2 A In a repossession? I don't understand. If I 2 Company to third parties?
3 repossess the vehicle, then I'm in control of the 3 MS. WALKER-PROBST: Objection; incomplete
4 collateral, right? 4 hypothetical.
5 Q Well, before the repossession? 5 JUDGE CHOATE: Let's just get through this.
6 A Before the repossession, no, that would be 6 THE WITNESS: I don't know.
7 something that Ford Motor Company, more specifically the 7 MS. ALBERT: I'd like to mark as Exhibit 9 Bates
8 dealership, would assist you as a customer with. We don't 8 ALB346 through 351.
9 manufacture, cut or produce keys. We don't even have 9 (Exhibit 9 was marked for identification and it
10 access to those codes. 10 is attached hereto)
11 Q Did Ford Motor Credit Company believe Ms. Albert 11 JUDGE CHOATE: I have a procedural question.
12 when she said she was getting threats? 12 Let's go off the record.
13 MS. WALKER-PROBST: Objection; not likely to lead 13 (Discussion off the record from 4:29 p.m. through
14 to the discovery of admissible evidence. 14 4:31 p.m.)
15 JUDGE CHOATE: Overruled. 15 BY MS. ALBERT:
16 MS. WALKER-PROBST: Lacks foundation. 16 Q Now, with regard to Ford Credit's conduct, did
17 THE WITNESS: Yes. Whatever you have told us, we 17 Ford Credit receive a phone call from Monica Jones on
18 are going to notate in the account and we are not going to 18 April 7 informing them where Ms. Albert would be?
19 determine what is -- without back-up documentation or 19 MS. WALKER-PROBST: What year?
20 without -- we are not going to pass judgment. That's not 20 MS. ALBERT: April 7, 2015.
21 what we are in business for. 21 THE WITNESS: No.
22 MS ALBERT: The next document we are going to 22 BY MS. ALBERT:
23 attach is Bates ALB334 through 345. 23 Q How did Monica Jones learn the car was
24 (Exhibit 8 was marked for identification and it 24 repossessed on April 6, 2015?
25 is attached hereto) 25 MS. WALKER-PROBST: Lacks foundation, calls for
Page 166 Page 168

1 speculation. 1 about a third party involvement here.
2 JUDGE CHOATE: Sustained. 2 MS. ALBERT: They are all connected to Monica
3 BY MS. ALBERT: 3 Jones. They were all working together.
4 Q Did Ford Motor Credit Company tell Monica Jones 4 JUDGE CHOATE: If you know, answer; if you don't
5 that the car was repossessed on April 6, 2015? 5 know, tell us you don't know.
6 A No. 6 THE WITNESS: I don't know. I have never seen
7 Q Do you know who told Monica Jones that the car 7 this.
8 was repossessed on April 6, 2015? 8 BY MS. ALBERT:
9 A Who told her? 9 Q Now I'm showing you what's marked as ALB 393 and
10 Q Yes. 10 394, which is an email about a bird getting stuck in a
11 A No. 11 tree and bleeding to death from attorney David Seal, along
12 Q Isn't it true, according to your own phone log, 12 with a second page showing he was charged once for
13 after April 6, 2015, Monica Jones had stopped calling Ford 13 possession of fire arm in his car. Do you see that?
14 Motor Credit informing them of where Ms. Albert would 14 A I see an email, yes, and a case summary.
15 be? 15 Q If you had that, if Ford Motor Credit Company had
16 A Yes. 16 that email, along with that case summary showing that at
17 Q But you have no indicia exactly who told you 17 least on one occasion David Seal had been caught with a
18 that, correct? 18 gun in his possession in his car without a permit, would
19 A Who told me what? 19 you have warned Ms. Albert, knowing that David Seal and
20 Q I mean, who told Monica Jones that she didn't 20 Monica Jones are friends, on April 6, 2015, knowing
21 need to call in on a daily basis anymore? 21 someone was at that parking lot?
22 A I don't know. I'm not aware of that 22 MS. WALKER-PROBST: Objection; incomplete
23 conversation. 23 hypothetical.
24 Q Why isn't there any notations in your system 24 JUDGE CHOATE: Overruled. Let him answer.
25 about Karen Rosear? 25 THE WITNESS: I don't know who David Seal is.
Page 169 Page 171
1 A I don't know. 1 BY MS. ALBERT:

2 Q Isn't it true Ms. Albert called Ford Motor Credit 2 Q Do you know who Cindy Brown is?
3 informing them that a person named Karen Rosear was 3 A I do not know who Cindy Brown is. I have heard
4 sending emails telling her to kill herself and said that 4 the name.
5 she and Megan had put out a description of the car with 5 Q Where did you hear the name from?
6 the VIN number and telling people with guns to shoot her 6 MR. BERKLEY: Objection, attorney-client
7 on sight, because she harms small children? 7 privilege.
8 A I don't know. 8 THE WITNESS: I just heard of it this morning.
9 MS. ALBERT: I'm handing you the next Exhibit, 9 BY MS. ALBERT:
10 which is L385 to 392. 10 Q Do you know why Ford Motor Credit Company has
11 (Exhibit 10 was marked for identification and it is 11 asked to depose Cindy Brown?
12 attached hereto) 12 A No.
13 BY MS. ALBERT: 13 MR. BERKLEY: Same objection.
14 Q Those are, in fact, emails from Karen Rosear to 14 MS. ALBERT: I will mark these emails as Exhibit
15 Ms. Albert telling her to go kill herself, correct? 15 11 and the photograph as Exhibit 12.
16 MS. WALKER-PROBST: Objection; lacks foundation. 16 (Exhibits 11 and 12 were marked for identification
17 JUDGE CHOATE: What relevance does that have in 17 and they are attached hereto)
18 this case? 18 BY MS. ALBERT:
19 MS. ALBERT: It has a lot, because -- 19 Q I am handing you what is marked at L395. This is
20 JUDGE CHOATE: Just tell me some. 20 a photograph from left to right, David Seal, Sherrie Moody
21 MS. ALBERT: Phone conversations that I actually 21 and Cindy Brown. Have you ever seen any of those three
22 had with Ford Credit, which was audiotaped, and I have the 22 people before
23 audiotape, and it is a very different version than what 23 MS. WALKER-PROBST: Objection to the extent
24 they put in the notes, so they actually had knowledge. 24 counsel is testifying.
25 JUDGE CHOATE: What about this? You're asking 25 JUDGE CHOATE: What's that?
Page 170 Page 172

1 MS. WALKER-PROBST: To the extent counsel is 1 accurate?
2 testifying. 2 A Yes.
3 JUDGE CHOATE: Overruled. To the extent counsel 3 Q If she had represented that she was a licensed
4 is testifying, she's not under oath. Let's just ask the 4 realtor in those notes and you had put them in your
5 question at hand. 5 system, would you have verified whether or not she was a
6 MR. BERKLEY: Beyond the scope. 6 licensed realtor?
7 THE WITNESS: I don't know these people. 7 A No.
8 BY MS. ALBERT: 8 Q Why not?
9 Q My question is, have you ever seen them before? 9 A There's no reason to.
10 A No, never. 10 Q Does Ford Credit have any system in place to
11 Q Now, do you see in this photograph how tall Cindy 11 protect their customers from being harassed?
12 Brown is? 12 A We have policies and procedures.
13 MS. WALKER-PROBST: Objection; lacks 13 Q What are those policies and procedures?
14 foundation. 14 A They are numerous.
15 JUDGE CHOATE: Overruled. There's a different 15 Q What does it generally require an employee of
16 way to do that. Looking at the person on the right on the 16 Ford Motor Credit Company to follow?
17 photograph, does it appear that she's taller than the 17 MS. WALKER-PROBST: Objection; vague as to what
18 others? 18 we are talking about regarding harassment.
19 THE WITNESS: She's taller than the person in the 19 JUDGE CHOATE: Overruled. You can answer if you
20 photograph. 20 can answer it succinctly.
21 JUDGE CHOATE: I think that is sort of 21 THE WITNESS: We have to abide by the Fair Credit
22 self-evident. 22 and Equal Opportunity Lending Act. We have to follow the
23 BY MS. ALBERT: 23 collection laws, you know, that keep customers -- these
24 Q You can see me. I represent I'm five-two. Am I 24 are just a couple of the many things -- keep customers'
25 giving you an accurate representation? 25 pertinent account information secure.
Page 173 Page 175
1 MS. WALKER-PROBST: Beyond the scope of the 1 MS. ALBERT: I'm handing you what is marked as
2 deposition notice. 2 406 and we will actually put this one in the record.
3 JUDGE CHOATE: Let's not have a demonstration 3 (Exhibit 13 was marked for identification and it
4 right now with this witness. We are better off just 4 is attached hereto)
5 sticking with the picture. 5 BY MS. ALBERT:
6 BY MS. ALBERT: 6 Q Do you know what a sovereign citizen is?
7 Q If you had known that Cindy Brown and the others 7 A I do not.
8 had called out a grand jury with other sovereign citizens, 8 Q What I have just handed you is a photo of Cindy
9 would you have warned Ms. Albert on April 6, 2015, that 9 Brown. It looks familiar from the other photo? Same
10 there were people outside the courthouse that had at least 10 person?
11 sent a photo to you that day? 11 A It looks familiar.
12 MS. WALKER-PROBST: Objection; calls for 12 Q And then next to it is a person who calls himself
13 speculation, improper hypothetical. 13 Chief Murray. Do you see that?
14 JUDGE CHOATE: Overruled. The question is would 14 A That's what it says below his picture, yes.
15 he have warned Ms. Albert? 15 Q And it clearly states in there that he's armed,
16 THE WITNESS: We didn't receive a photo. 16 correct?
17 JUDGE CHOATE: And he's not the FBI and he's not 17 MS. WALKER-PROBST: Objection; the document
18 the local sheriff, he's a car maker and a credit supplier. 18 speaks for itself.
19 BY MS. ALBERT: 19 JUDGE CHOATE: It does.
20 Q Did Monica Jones ever represent to you that she 20 BY MS. ALBERT:
21 was a licensed realtor? 21 Q Do you know who Cliven Bundy is?
22 A No. 22 A No.
23 Q If it had stated in your notes that you produced 23 Q If you knew that Cliven Bundy was a sovereign
24 in this discovery that she had represented that she was a 24 citizen extremist, who had over 200 people armed at his
25 licensed realtor, would you consider those notes to be 25 ranch and he was with Cindy Brown during this time period
Page 174 Page 176

1 and Monica Jones when you were paying them -- 1 BY MS. ALBERT:
2 JUDGE CHOATE: These are long compound 2 Q Do you have a policy and procedure that you are
3 questions. 3 supposed to follow with regard to contacting third
4 MS. ALBERT: I'm going to shorten it for you. 4 parties?
5 JUDGE CHOATE: It is improper and drawing this 5 A Yes.
6 out, and at some point it becomes badgering of the 6 Q Did you produce those in this case?
7 witness. It's not designed to elicit information from the 7 A Yes.
8 witness. It's designed to do something you want to do. 8 Q Were those the policies and procedures that were
9 Your questions have to be designed to draw information 9 in effect at the time that the events and transactions
10 from him. 10 occurred in this action?
11 MS. ALBERT: Okay. 11 A I would have to see those policies or procedures
12 BY MS. ALBERT: 12 to verify the date.
13 Q Did you tell Monica Jones that you were going to 13 Q So long as the date is correct on those policies
14 depose her the other week? 14 and procedures, those would be the policies and procedures
15 A I don't know. 15 that the employees of Ford Motor Credit Company were
16 Q Did she ever produce to you the video that was 16 supposed to follow, correct?
17 made on the day of April 6, 2015, when I exited the 17 A Correct.
18 courthouse? 18 Q Did you supply policies and procedures with
19 A No. 19 regard to titling in this case?
20 Q Have you ever looked at her Face Book page? 20 A Yes.
21 A No. 21 Q Did you also supply the policies and procedures
22 Q Previously we had disclosed a photo of the car 22 with regard to employing outside vendors to do the titling
23 being towed out of the Santa Ana courthouse parking lot on 23 in this case?
24 Face Book with Monica Jones, Cindy Brown, and the rest of 24 A No. We don't utilize outside vendors for
25 the gang, asserting that I had never registered the 25 titling.
Page 177 Page 179
1 vehicle. How would Monica Jones know that? 1 Q So, is it your testimony that all the policies
2 MS. WALKER-PROBST: Objection; lacks foundation, 2 and procedures supplied by titling in this case, every
3 calls for speculation. 3 single one of them, applied to employees of Ford Motor
4 JUDGE CHOATE: Sustained. 4 Credit?
6 Q Did you ever tell Monica Jones that I did not 6 Q Were the employees trained on those policies and
7 register my vehicle? 7 procedures that worked on my account?
8 A No. 8 A Yes.
9 Q Did you ever tell any of the persons that I just 9 Q And were the employees of Ford Motor Credit
10 mentioned that I never registered my vehicle? 10 trained on the policies and procedures with regards to
11 A No. 11 communications with third parties that worked on my
12 Q Did you ever tell anyone that I never registered 12 account?
13 my vehicle? 13 A Yes.
14 MS. WALKER-PROBST: Objection; vague as to 14 Q Did you supply all the relevant policies and
15 "anyone." 15 procedures with regard to repossessions?
16 JUDGE CHOATE: Overruled. Did you ever tell 16 A Yes.
17 anyone? 17 Q Were all the employees of Ford Motor Credit
18 THE WITNESS: No. 18 trained on those policies and procedures by Ford Motor
19 JUDGE CHOATE: I suppose you told your attorneys? 19 Credit?
20 THE WITNESS: We told the outside contractor, 20 A All employees? There's --
21 which we read the notes on, that the vehicle was 21 Q All employees that worked on my account.
22 registered in Nevada. 22 A Every employee that worked on your account, no.
23 JUDGE CHOATE: Apart from what was already 23 Q Was Dedicated Recovery given those policies and
24 testified to, anybody else? 24 procedures when you hired them to do the repossession?
25 THE WITNESS: No. 25 A Given which policies and procedures?
Page 178 Page 180

1 Q The repossession policies and procedures. 1 on Civic Center Drive in Santa Ana.
2 A At the time of assignment, no. 2 A I may have. I don't know.
3 Q How did Ford Motor Credit Company supervise the 3 MS. ALBERT: I'll mark as exhibit next in order,
4 repossession agency's manner and method of repossessing 4 I think it's supposed to be 5L553554. It's dark.
5 the vehicle to ensure it was not an illegal repossession? 5 ` (Exhibit 15 was marked for identification and it
6 A It is the repossession company's agreement with 6 is attached hereto)
7 us that they will follow all laws and regulations when 7 BY MS. ALBERT:
8 repossessing the vehicle. 8 Q Have you ever seen those photos before?
9 Q Did Ford Motor Credit Company place on my 9 A Never.
10 Experian credit report that my account was charged off? 10 MS. ALPERT: I'll represent to you in your phone
11 MS. WALKER-PROBST: Beyond the scope of the 11 activity log, your person that you hired to do the
12 designation. 12 collection had stated that there was a carport and no
13 JUDGE CHOATE: Overruled. What is your question? 13 access to park a car in front of my home.
14 BY MS. ALBERT: 14 I'd like to mark as the next exhibit, Exhibit 16,
15 Q Did Ford Motor Credit Company put on my Experian 15 two photos, actually four photos.
16 credit report that my account was charged off? 16 (Exhibit 16 was marked for identification and it
17 JUDGE CHOATE: Charged off for a particular 17 is attached hereto)
18 amount? 18 BY MS. ALBERT:
19 MS. ALBERT: The amount shows as charged off for 19 Q I'll represent to you that is a photo of my home
20 $3,586 as written and $3,864 past due as of January 2016. 20 mocked up a bit by Monica Jones, but do you see that, in
21 JUDGE CHOATE: Did Ford Credit write that off? 21 fact, there is no carport?
22 THE WITNESS: We did report a charge-off. 22 A It's hard to ascertain from this photo.
23 BY MS. ALBERT: 23 JUDGE CHOATE: Have you ever been out there?
24 Q Had you also reported this as a repossession? 24 THE WITNESS: No.
25 A I don't know how the Bureau interprets the 25 JUDGE CHOATE: Okay. Next question?
Page 181 Page 183
1 information we send them. I can't testify to that. 1 BY MS. ALBERT:

2 MS. ALBERT: I'd like to mark as the next exhibit 2 Q Were you aware Ms. Albert was going to the DMV in
3 in order, this one page. This will be Exhibit 14. 3 an attempt to register her vehicle in December 2013?
4 (Exhibit 14 was marked for identification and it 4 A December 2013, which date?
5 is attached hereto) 5 Q The whole month?
6 BY MS. ALBERT: 6 A The entire month?
7 Q What we have marked as Exhibit 14, is that 7 Q Yes, several times.
8 information contained on that page of the Experian credit 8 A Yes, we had received a fax on December 31.
9 report the information that was actually given to Experian 9 Q Ford Motor Credit Company represented that it
10 from Ford Motor Credit? 10 would make sure that the title department would send the
11 MS. WALKER-PROBST: Objection; lacks foundation, 11 information to the DMV, and that's why you received the
12 hearsay, beyond the scope of the designation and 12 fax in December 2013 with the documents, correct?
13 deposition notice. This is not being produced as a PMK on 13 A That's not correct.
14 Ford Credit reports. 14 Q Were you aware that Friendly Ford sued Ms. Albert
15 JUDGE CHOATE: Overruled. Do you understand the 15 and she had to fly to Las Vegas to attend those
16 question? 16 hearings?
17 THE WITNESS: I do understand the question. 17 MS. WALKER-PROBST: Same objection regarding
18 JUDGE CHOATE: Do you know the answer? 18 attorney-client privilege.
19 THE WITNESS: I don't know the answer. 19 JUDGE CHOATE: Do you know the answer to that?
20 JUDGE CHOATE: Thank you. You just answered. 20 THE WITNESS: I know that they sued you. I don't
21 BY MS. ALBERT: 21 know they sued you in Las Vegas.
22 Q Have you ever seen the parking lot of the Orange 22 BY MS. ALBERT:
23 County Superior Court? 23 Q How did you think I would get there?
24 A Which one? 24 JUDGE CHOATE: Argumentative at this point. This
25 Q The one located at Central Justice Center located 25 examination is becoming very argumentative.
Page 182 Page 184

1 BY MS. ALBERT: 1 Q Is Dedicated Recovery the full legal name?
2 Q The summary judgment papers, not this new summary 2 A I do not know the full legal name for Dedicated
3 judgement, but the old summary judgment papers had a 3 Recovery.
4 declaration attached by Ford Motor Credit. Do you know 4 Q Do you know what Lojack does?
5 who wrote that declaration? 5 A I am familiar with the product.
6 A I would have to see it. 6 Q What is Lojack?
7 JUDGE CHOATE: Is that your declaration? Is that 7 A Lojack is a vehicle recovery system.
8 what you are referring to, something he signed? 8 Q What does it do?
9 MS. ALBERT: I'm not sure if it was his name or 9 A Do you mean how does it work?
10 not. 10 Q What is it supposed to do for a person that
11 MS. WALKER-PROBST: I believe it's Ms. Zapeda. 11 purchases it?
12 JUDGE CHOATE: Do you have it? Do we know where 12 A If their car is ever stolen, then the way I
13 it is? 13 understand it is that Lojack -- the customer, Lojack and
14 MS. WALKER-PROBST: Just show it to him. 14 the police department all work together in order to
15 MS. ALBERT: I don't have a copy of that with me. 15 recover that vehicle.
16 I don't know where the first pages went. It was right 16 Q Do you know what Hijack is?
17 here. 17 A Hijack?
18 THE WITNESS: Here it is. Here it is right here. 18 Q Yes.
19 I can't read it. This is it. 19 A Not specifically, no.
20 JUDGE CHOATE: What is it that you want to ask 20 Q Does Lojack use a GPS system?
21 him about the Zapeda declaration? 21 A Yes.
22 BY MS. ALBERT: 22 Q Does Lojack remotely turn off the computer system
23 Q Did you in preparation for your testimony today, 23 in the vehicle?
24 did you go over her declaration with her? 24 MS. WALKER-PROBST: Lacks foundation, calls for
25 A I cannot remember. 25 speculation.
Page 185 Page 187
1 Q Can you explain why the repossession company that 1 THE WITNESS: No.
2 was attached to her declaration was not licensed at the 2 JUDGE CHOATE: Overruled, and the answer may
3 time of the repossession? 3 remain. He doesn't know.
4 MS. WALKER-PROBST: Objection; assumes facts. 4 BY MS. ALBERT:
5 JUDGE CHOATE: Were you aware whether or not the 5 Q Does the Hijack system remotely turn off the
6 repossession company was licensed at the time of the 6 computer system?
7 repossession? 7 MS. WALKER-PROBST: Lacks foundation.
8 THE WITNESS: I'm aware, yes, they were 8 JUDGE CHOATE: Overruled. Do you know that
9 licensed. 9 answer?
10 BY MS. ALBERT: 10 THE WITNESS: No.
11 Q Can you explain why Ms. Zapeda had only attached 11 BY MS. ALBERT:
12 one sheet supporting the assertion that the repossession 12 Q What is the difference between Lojack and the
13 company that you used to repossess my car was not 13 security system that was purchased on the purchase
14 licensed? I'm not talking about what you supplied -- 14 contract?
15 JUDGE CHOATE: Are you asking for a reason that 15 A The security system is a theft deterrent. Lojack
16 somebody did that? How would he know her reason? Maybe 16 is a theft recovery system. Those are the differences.
17 she was having a bad day. 17 Q What does the security system do?
18 BY MS. ALBERT: 18 A Normally if it is armed, it will create some kind
19 Q Dedicated Recovery Service that existed before my 19 of notification alarm, whatever it may be, that somebody
20 car was repossessed was not owned by Scott, was it? 20 is trying to break into the vehicle.
21 A I don't know the ownership of Dedicated Recovery. 21 Q And if the keys and the fob are stolen from the
22 Q Do you know the actual full legal name of the 22 car, can the security system be armed?
23 entity Ford Motor Credit contracted with to repossess my 23 A I don't know.
24 car in 2015? 24 Q If the keys and fob are stolen from the car, can
25 A No, I do not know the full legal name. 25 the Lojack system still work?
Page 186 Page 188

1 A I don't know. 1 two minutes later at 16:25 on the same day, is that
2 Q Did Ford Motor Credit Company report my payments 2 another outside call?
3 as late at any time before they repossessed the vehicle? 3 A No. That's stating that we talked to our outside
4 A Yes. 4 contractor, who called to advise borrower may be calling,
5 Q Did Ford Motor Credit Company report my payments 5 is trying to find out how they got info on vehicle
6 as late before February 13, 2014? 6 location, appears we have informant, did not discuss that
7 A I don't know. 7 with borrower, transferred to skip, Extension 82196."
8 Q Did Ford Motor Credit company tell Ms. Albert 8 Q And did the borrower call in on April 6 2015?
9 that the missing title was not its problem? 9 A No.
10 JUDGE CHOATE: He's testified to that. Are you 10 Q And after Ford Motor Credit Company was informed
11 asking if those exact words were used? 11 that they were advised by the repossession company that
12 MS. ALBERT: No, not the exact words, the 12 the repossession company wasn't giving any information out
13 understanding. 13 to the borrower, did Ford Motor Credit Company then inform
14 THE WITNESS: Yes, it was conveyed. 14 the borrower how to get her personal property?
15 BY MS. ALBERT: 15 A We were not aware if there was personal property
16 Q Did Ford Motor Credit Company continue to collect 16 in the vehicle or not.
17 payments from Ms. Albert on the vehicle after Ford Motor 17 Q Isn't it true you have a policy and procedure
18 Credit Company was aware that she did not receive title? 18 where you are supposed to give a written inventory if
19 JUDGE CHOATE: You asked him that and he's 19 there's anything worth more than $300 in the vehicle?
20 testified already. 20 A I don't know. I would have to read that policy
21 BY MS. ALBERT: 21 and procedure.
22 Q Did Ford Motor Credit Company ever notify 22 Q Did you at any time ever supply a written
23 Ms. Albert where she could pick up her personal property 23 inventory for the borrower, inventorying all of the
24 that was located in the vehicle when it was repossessed on 24 personal property that was still in the vehicle?
25 April 6, 2015? 25 A No. That's the responsibility of the
Page 189 Page 191
1 A No. That's the responsibility of our outside 1 repossession company.

2 contractor, the repossession company. 2 Q Did Ford Motor Company ever do anything to
3 Q Did Ford Motor Credit Company ever inform 3 confirm that the repossession company complied with that
4 Ms. Albert that she needed to contact the repossession 4 policy or procedure and created an inventory of all items
5 company if she wanted to obtain her personal property? 5 that were worth over $300 in value?
6 A We would have advised you that had you called in 6 A Ask that question again. I'm sorry.
7 and asked. 7 JUDGE CHOATE: That was three questions. Just
8 Q I want to refer you back to Exhibit 5. You can 8 ask them one at a time.
9 go to page 108. 9 BY MS. ALBERT:
10 A Okay. 10 Q To recap, you had stated earlier that Ford Credit
11 Q If you look at a notation at the hour 16:23 -- 11 had basically told Dedicated Recovery, who we don't know
12 A Okay. 12 who that is, but that's a shorthand name for some
13 Q It says OSC. What does OSC stand for? 13 repossession agent, that it was their responsibility to
14 A Outside contractor. 14 deal with the personal property, correct?
15 Q Did the outside contractor call in or did you 15 A That's part of our agreement. That's part of an
16 call them? 16 executed agreement.
17 A We telephoned, "T" stands for telephone, 17 Q I represent to you one of your policies and
18 non-customer, outside contractor, other. 18 procedures is that there must be a written inventory if
19 Would you like me to read it for you? "Spoke 19 there is any personal property over $300 in value.
20 with Jamie, Dedicated Recovery, borrower has been calling 20 Assuming that to be true, obviously this won't
21 and questioning outside contractor on how we got info to 21 come in at trial if I'm wrong, but assuming that to be
22 pick up the vehicle. Started getting aggressive. Outside 22 true, did Ford Motor Credit Company do anything to
23 contractor refused to answer any questions and advised 23 supervise the repossession agency to ensure that they did
24 borrower to call us for further information." 24 comply with your policy and procedure?
25 Q And then if you look at the next line, which is 25 A Since we are going to do a hypothetical, ma'am,
Page 190 Page 192

1 if you would have called in to me or if you would have 1 registration papers? Answer yes or no.
2 called into Ford Credit and insinuated that you were not 2 THE WITNESS: No.
3 able to pick up your personal property, we would have 3 BY MS. ALBERT:
4 interjected and done everything within our power to make 4 Q Do you know what happened to the Karaoke machine
5 sure that it was returned to you. 5 and all of the other personal property that was located
6 Q Why did you use a repossession company that was 6 inside the car on April 6, 2015?
7 located in the Inland Empire? 7 A According to our agreement with all of our
8 A We have been doing business with Dedicated 8 repossession companies, they are required to hold that
9 Recovery for a very long time. 9 property for an X-amount of time period, which gives you
10 Q Why wouldn't you use someone that was local? 10 as a customer ample time to get ahold of them and pick
11 A They may have agents that are local and do run 11 that up.
12 this area. I don't know how many agents they have or 12 Q Do you have any writing to show that I was ever
13 where they are located at, but they have indicated to us 13 notified where that location was where I could pick up
14 that they are willing to -- they indicated to us which zip 14 that personal property?
15 codes they are willing to work for us in, and if that is 15 A I don't know.
16 one of the -- and it is up to them to accept the 16 Q Have you listened to the audiotape of my
17 assignment or not. If they don't want to work in Orange 17 conversation with the repossession company on April 6,
18 County, they don't have to accept the assignment. 18 2015?
19 Q Did you ever offer to pay for the loss of the 19 A No.
20 personal property that was still in the vehicle that was 20 Q Why not?
21 repossessed at the courthouse parking lot on April 6, 21 A I didn't know it existed.
22 2015? 22 MS. WALKER-PROBST: If you have a copy, it has
23 MS. WALKER-PROBST: Assumes facts. 23 not been produced.
24 JUDGE CHOATE: Well, we mentioned personal 24 MS. ALBERT: Yes, it was. It was produced and
25 property I would guess conservatively twenty times today. 25 listened to at the last deposition, which was in October
Page 193 Page 195
1 I don't have a clue what it is. Is it a row boat? What 1 2016.

2 personal property are we talking about? Is it the keys? 2 JUDGE CHOATE: What tape? Do you have a tape?
3 Is it the fob? 3 MS. ALBERT: It's an audio. In fact, five
4 MS. ALBERT: I can list it. 4 audiotapes. If you read your own deposition, you would
5 JUDGE CHOATE: Nobody ever mentioned word one in 5 know that.
6 this entire lengthy transcript about the personal property 6 MS. WALKER-PROBST: I don't know what deposition
7 you're asking him questions about. What is the personal 7 you are referring to.
8 property? Was it a diamond ring? 8 MS. ALBERT: My deposition.
9 MS. ALBERT: All of the court papers, all of the 9 MS. WALKER-PROBST: Thank you.
10 animal accessories, all the pet accessories, the Karaoke 10 BY MS. ALBERT:
11 machine, all the other electronics that were in the car. 11 Q Did Ford Motor Credit Company ever advise in
12 That's including, but not limited to. 12 writing of the date and time of the auction of my
13 JUDGE CHOATE: Thank you. 13 vehicle?
14 BY MS. ALBERT: 14 A We did, yes. We did send you notification of
15 Q Did you ever offer to reimburse the payment for 15 intent to sell.
16 those items that were in the car? 16 Q That wasn't my question. My question was did you
17 A No. 17 give me the date and time of the auction after the
18 Q Did you ever offer to reimburse the payment for 18 repossession?
19 the replacement of the keys and fob? 19 A No.
20 A No. 20 Q Was there any point in time between April 29,
21 Q And did you ever offer to reimburse the payment 21 2013, to April 6, 2015, that Ford Motor Credit Company
22 of the registration papers that were converted and never 22 executed or waived a monthly payment?
23 given to Ms. Albert? 23 A No.
24 MS. WALKER-PROBST: Assumes facts. 24 JUDGE CHOATE: Except for the charge-off. She
25 JUDGE CHOATE: Did you ever offer to pay for the 25 said there was a charge-off, right, of the balance after
Page 194 Page 196

1 this was over with? 1 JUDGE CHOATE: If you know.
2 THE WITNESS: Yes. Once we determined that the 2 THE WITNESS: I don't know.
3 account is totally uncollectible and we have exhausted 3 JUDGE CHOATE: That's the answer, if that's your
4 everything in regard to recouping any costs, then we 4 truthful answer.
5 report it as a charge-off. 5 THE WITNESS: I don't know.
7 Q Did Ms. Albert ever charge you with grand theft 7 Q Did you do anything to try to identify the person
8 auto on April 6, 2015? 8 that was on the audio tape that I supplied who called
9 A I don't know. 9 herself Becky in March 2015?
10 MS. WALKER-PROBST: Lacks foundation, calls for 10 A I don't know if I listened to that tape.
11 speculation. 11 Q Why not?
12 JUDGE CHOATE: Sustained. 12 A Why don't I know?
13 Are we done? 13 Q No. Why didn't you listen to the tape? It was
14 MS. ALBERT: I'm going through my pleadings to 14 discovery that was produced in this case. You were
15 make sure. 15 supposed to come in here prepared.
16 BY MS. ALBERT: 16 JUDGE CHOATE: He testified that he doesn't know
17 Q Do you know who Becky is that I spoke to at Ford 17 whether he's listened to the tape. You don't need to
18 Motor Credit Company 2015, March 19th? 18 lecture him now.
19 A No. I don't know who that person is. 19 MS. ALBERT: No, he said he wouldn't, didn't.
20 Q Did you ask anyone to see if she was still 20 MS. WALKER-PROBST: Your question is very
21 employed with Ford Motor Credit Company? 21 unclear.
22 A I don't know who that person is. 22 MS. ALBERT: He said he did not.
23 JUDGE CHOATE: Do you want to reference something 23 JUDGE CHOATE: Why don't you just play the tape
24 so that he can see what you're talking about? 24 and ask him if he's heard it before?
25 MS. ALBERT: To my pleadings. 25 Ask another question, why don't you?
Page 197 Page 199
1 THE WITNESS: I don't know who Becky is, no. 1 BY MS. ALBERT:
2 BY MS. ALBERT: 2 Q Isn't it true I could not trade in that vehicle
3 Q Did you listen to the audiotape that was produced 3 without perfected title?
4 from March 19, 2015, in this case, my conversation with 4 A That is true.
5 Becky from Ford Motor Credit Company? 5 Q Isn't it true I could not register that car
6 MS. WALKER-PROBST: I don't know what you are 6 without the title?
7 talking about. Who produced it? 7 A I don't know that answer.
8 MS. ALBERT: I did. 8 Q Isn't it true I needed registration in order to
9 JUDGE CHOATE: Why don't you rephrase the 9 get license plates on the car?
10 question and remove the term "Becky," because we don't 10 A They all work hand in hand -- license plate,
11 know who Becky is. 11 registration and title are all produced at the same time.
12 MS. ALBERT: She identified herself as Becky. 12 That's the Department of Motor Vehicles.
13 JUDGE CHOATE: Just ask the question again. 13 Q What do you mean by "They are all produced at the
14 Let's wrap this up. It's 5:30. We have a 14 same time"?
15 meeting we have to do. 15 A On new vehicles, when the dealership takes the
16 MS. ALBERT: I know. 16 paperwork or sends it in to the Department of Motor
17 JUDGE CHOATE: There's a yes or no answer to that 17 Vehicles, there's normally one form that the dealership
18 question, if you want to know. 18 sends in. The DMV uses that and puts it into their
19 BY MS. ALBERT: 19 system. I cannot talk to how their system works, but from
20 Q Are your customer representatives told to lie 20 that one form -- there's a license plate assignment, the
21 about their name? 21 registration is created and the title is created.
22 MS. WALKER-PROBST: Argumentative. 22 Q Did you ever send that form in to the California
23 BY MS. ALBERT: 23 Department of Motor Vehicles?
24 Q Did someone represent themselves to be Becky on 24 A I don't even have access to that form.
25 March 19, 2015, working for your company? 25 Q I show a fax from Ford Motor Credit going to a
Page 198 Page 200

1 place in San Diego County which Ford Motor Credit Company 1 MR. BERKLEY: We didn't ask for you to pay for
2 produced in this case. Do you recall that fax? 2 it. We'll pay for the copy of the deposition transcript.
3 MS. WALKER-PROBST: Vague. 3 This is what is done every single time. Nobody goes into
4 THE WITNESS: No. 4 a court reporter's office and signs the verification
5 MS. ALBERT: I'll find it. I believe it's at 5 anymore.
6 Bates stamp 165. 6 JUDGE CHOATE: So this will not be the exception
7 Friendly Ford would not produce any documents 7 to the rule.
8 pursuant to subpoena, neither would Dedicated Recovery. 8 MS. ALBERT: All of my clients do, even when they
9 This is all the stuff that I have received from you. I am 9 are a couple of hundred miles away.
10 looking for -- 10 JUDGE CHOATE: We can go off the record.
11 JUDGE CHOATE: Is this the one you are looking 11 (Discussion off the record)
12 for right here? 12 JUDGE CHOATE: We just peeled the last skin on
13 MS. ALBERT: It's only part of it. 13 the onion on that one. The original will be sent to
14 JUDGE CHOATE: Do you want to go off the record? 14 counsel for the witness. He will have thirty days out
15 MS. ALBERT: Yes. 15 from the time you receive it, thirty days to return the
16 (Recess from 5:25 p.m. through 5:29 p.m.) 16 signed copy of the deposition.
17 JUDGE CHOATE: We would like to thank and excuse 17 MS. ALBERT: If I don't receive notification of
18 you from this deposition. We appreciate your time and 18 the signed original, I can use a copy as if it were an
19 attention and your patience. 19 original.
20 COURT REPORTER: Would you like to order a copy 20 (The deposition concluded at 5:35 p.m.)
21 of the deposition? 21
22 MS. WALKER-PROBST: Yes. 22
23 (Discussion off the record) 23
24 JUDGE CHOATE: We are going to enter into a 24
25 stipulation that the court reporter can be relieved of her 25
Page 201 Page 203
1 duties. Mr. Fernau will review the deposition transcript 1 PENALTY OF PERJURY CERTIFICATE
2 and within a period of time that we can agree to, he will 2
3 sign it and make any changes to it. 3 I hereby declare I am the witness in the within
4 MS. WALKER-PROBST: Mr. Fernau travels all over 4 matter, that I have read the foregoing transcript and
5 the country. He is going to Hawaii next week. It is 5 know the contents thereof; that I declare that the same
6 unduly burdensome to require him to go into the reporter's 6 is true to my knowledge, except as to the matters which
7 office and sign it. That's not typically the way things 7 are therein stated upon my information or belief, and as
8 are done. 8 to those matters, I believe them to be true.
9 MS. ALBERT: It's always done in my banking 9 I declare being aware of the penalties of perjury,
10 cases. 10 that the foregoing answers are true and correct.
11 JUDGE CHOATE: My recommendation is that's 11
12 exactly what is was going to happen, not that he goes in, 12
13 but get him a copy, let him read it within a reasonable 13
14 period of time. I'll issue an order to that effect. It's 14
15 part of the discovery process, so that's reasonable. 15 Executed on the _____ day of _______________, ____,
16 Failing that, I have to take action to do 16 at _________________________, _________________________.
17 something, but we don't need to burden any of our 17 (CITY) (STATE)
18 witnesses. It's not in our interest. 18
19 ` MR. BERKLEY: Just to be clear, a copy will be 19
20 provided to Mr. Fernau's attorney. Mr. Fernau will have 20
21 an opportunity to review it and execute the verification 21 ______________________________________
22 page on the back within a reasonable time, and we'll send 22 BRIAN FERNAU
23 a copy of the signed verification electronically to both 23
24 the court reporter and Ms. Albert. 24
25 MS. ALBERT: I'm not paying for your copy. 25
Page 202 Page 204

1 STATE OF CALIFORNIA ) 1 ERRATA SHEET
) ss: 2
2 COUNTY OF ORANGE ) 3 If any corrections to your deposition are necessary,
3 indicate them on this sheet, giving the change, page
4 I, JOYCE GRIFFITH, do hereby certify: 4 number, line number and reason for change.
5 5 PAGE LINE FROM TO
6 That I am a duly qualified Certified Shorthand 6 ____ ____ _____________________ _____________________
7 Reporter, in and for the State of California, holder of 7 Reason ________________________________________________
8 certificate number 11010, which is in full force and 8 ____ ____ _____________________ _____________________
9 effect and that I am authorized to administer oaths and 9 Reason ________________________________________________
10 affirmations; 10 ____ ____ _____________________ _____________________
11 That the foregoing deposition testimony of the 11 Reason ________________________________________________
12 herein named witness was taken before me at the time and 12 ____ ____ _____________________ _____________________
13 place herein set forth; 13 Reason ________________________________________________
14 That prior to being examined, the witness named 14 ____ ____ _____________________ _____________________
15 in the foregoing deposition, was duly sworn or affirmed 15 Reason ________________________________________________
16 by me, to testify the truth, the whole truth, and 16 ____ ____ _____________________ _____________________
17 nothing but the truth; 17 Reason ________________________________________________
18 That the testimony of the witness and all 18 ____ ____ _____________________ _____________________
19 objections made at the time of the examination were 19 Reason ________________________________________________
20 recorded stenographically by me, and were thereafter 20 ____ ____ _____________________ _____________________
21 transcribed under my direction and supervision; 21 Reason ________________________________________________
22 That the foregoing pages contain a full, true 22 ____ ____ _____________________ _____________________
23 and accurate record of the proceedings and testimony to 23 Reason ________________________________________________
24 the best of my skill and ability; 24
25 _________________________________ _____________________
25 Signature of Deponent Date
Page 205 Page 207
1 I further certify that I am not a relative or

2 employee or attorney or counsel of any of the parties,
3 nor am I a relative or employee of such attorney or
4 counsel, nor am I financially interested in the outcome
5 of this action.
6
7 IN WITNESS WHEREOF, I have subscribed my name
8 this ____ day of _____________, ____.
9
10
11 ______________________________________
12 JOYCE GRIFFITH, CSR No. 11010
13
14
15
16
17
18
19
20
21
22
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Page 206

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2:10 104:3 4/29/13 130:10,14
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20 76:4,12 141:17 142:2 4:01 155:17
21 79:3 85:14 7/22 120:2
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24 133:14 7/24 120:4
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25 146:5 147:6 148:12,14 7/25 120:6
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2008 14:16,21 7:00 22:6
26 44:14 122:7,14 124:17 442-7110 3:18
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2013 18:20,25 27:25 28:3 5 702-217-5625 113:13
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30:11 31:15 33:20 39:19
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132:14,19,20 135:24 202:4 203:8 205:18
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ALB346 168:8 150:21,25 151:3,9,12 Angeles 8:1 133:15
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ALB553-AMB554 5:12 169:14 170:2,9,13,15,19
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almost 118:8 160:2 38:25 54:19 70:2 82:17
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19:5,20 20:4,8,22 21:22 178:5 179:1 181:14,19 96:23 108:13 110:4
along 15:3 37:9 47:15 115:12,15,20 122:3
22:5,16 23:10 24:5 25:8 181:23 182:2,6,21 183:3 53:7 59:19 102:9 171:11 123:8 127:17 144:10
25:14,18 26:1,18,20 183:7,18 184:1,2,14,22 171:16 158:13 159:1 171:4,24
27:1,8 28:6,13 29:1,8 185:1,9,15,22 186:10,18
31:2 32:1,20 33:4,15,23 188:4,11 189:8,12,15,17 ALPERT 183:10 175:19,20 182:18,19
34:9 35:5,18 36:14 189:21,23 190:4 192:9 184:19 188:2,9 190:23
already 26:18 94:21 195:1 198:17 199:3,4
37:12,20,23 38:15 39:3 194:4,9,14,23 195:3,24 96:17 101:22 105:4 200:7
39:10 40:14 41:11,21 196:3,8,10 197:6,7,14 141:4 142:25 147:2
42:9,24 43:5,7,22 44:1,3 197:16,25 198:2,8,12,16 answered 10:22,23 60:3
150:20 178:23 189:20
44:10,12 45:14 46:1,13 198:19,23 199:6,19,22 88:20 115:2 182:20
51:6,12 52:1 53:1 54:2 200:1 201:5,13,15 202:9 also 11:17 14:1 28:15
54:22 55:4,8,14,20 202:24,25 203:8,17 29:9,18 47:15 59:18 answering 149:5,9
56:12,24 57:20 60:5,16 62:10 67:13 68:23 69:2 answers 204:10
60:19,22 61:3,11,18,19 Alberts 153:16 83:22 85:4 96:14 97:10
61:24 62:5,8,12,19 Albert's 4:10 18:20 27:25 99:25 102:12 117:22,25 any 8:15,21 9:4,15 10:17
63:13,19,23 64:19 65:1 28:3 33:6,10 52:7,11,14 119:8,12,16 123:2 11:25 12:11 15:20 16:10
65:3,8 66:12,14,20 67:8 53:17 64:4,16 95:16 133:24 134:14 179:21 16:18 19:10 23:25 38:9
67:19 68:5,7,13,15 69:1 111:2 153:24 164:2 181:24 38:10 41:24 42:15 43:20
69:3,10,12,18 70:11,13 46:16,17 47:19 48:3,6,7
ALBERT-SHERIDAN although 10:12,16 11:4 48:14,24 49:2,5,9,12,15
71:1,2,9,18 72:3,5 73:2
1:8,11 2:8,11 120:17 49:18,23 50:3,19 53:19
73:7,9,13,16,21 75:3,5
77:8,11 78:2,7 83:7,12 alert 83:10,15 Alvaros 152:7 58:21 60:25 64:12,19
83:17 85:6 86:18,20 66:21 69:17,25 74:11
alerted 150:20 always 76:20 202:9 78:2 84:24 87:23 89:3
87:5 88:5 89:1,11,13
91:1,16 92:6,10,23 all 21:5,10 27:18 32:8 am 17:19 18:1,22 20:14 89:11,13,14 93:13
93:16,21 94:18 95:13 35:14,22 36:22,23 37:9 23:11 44:25 66:7 77:12 101:20 102:18 106:16
96:11 97:9,20,21 99:9 37:22 38:2 55:11 57:19 78:1 95:17 104:5,17 106:23 110:21 113:14
99:10 100:19 103:7,14 66:8 67:11 76:17 77:1 172:19 173:24 187:5 114:4 117:8,9 118:10,17
104:2,9,14,20,22 105:19 85:3 87:17 92:6 98:4,6 201:9 204:3 205:6,9 121:18,20,23 123:9
106:2,9,19,22 107:18 99:6 100:3 111:7 114:22 206:1,3,4 125:14 128:21 138:5
108:6,16 109:11,16 119:14 121:25 122:5 140:9,13,21 141:1
amortization 100:12,13 143:14 148:2,10 153:16
110:6,20 111:11,18,20 128:12 130:4 131:21
111:23 112:22 113:1,5 135:12 142:9 143:4,5 amount 54:3 58:16 59:3,9 154:3 162:1,18 164:4,9
115:7,20,24 117:9,12 145:3 150:25 154:24 60:17 61:25 62:7,11 169:24 172:21 175:10
118:15 119:24 120:6,15 162:18 167:15 171:2,3 63:6,10,13,19 88:3 178:9 189:3 190:23
121:6,7,17,19 122:6,10 180:1,14,17,20,21 181:7 100:1,8 101:12,13,14,15 191:12,22 192:19
122:12,15 126:16,22 187:14 191:23 192:4 129:5 181:18,19 195:12 196:20 197:4

201:7 202:3,17 206:2 70:15 71:4,9 72:10 assault 167:9 attention 65:13 201:19
207:3 88:11 99:10,20 121:22
asserting 56:7 177:25 attorney 106:5 113:18
124:21,23 125:1,2 129:4
anybody 35:2 76:16 120:3 171:11 202:20
157:3 159:13,25 160:2,5 assertion 186:12
90:20 178:24 206:2,3
160:7 162:24 163:2,6,14
anymore 169:21 203:5 164:3 165:4 168:18,20 assign 28:14 attorney-client 9:9 29:4
168:24 169:5,8,13 assigned 84:3 38:6,22 44:21 158:16,18
anyone 12:10 13:2 129:24
171:20 174:9 177:17 172:6 184:18
178:12,15,17 197:20 assignment 17:23 18:1
189:25 191:8 193:21
21:2 28:14 29:9,12,16 attorneys 24:3,7 178:19
anything 9:16 47:6 53:16 195:6,17 196:20,21
69:12 70:13 76:17 91:14 197:8 29:24 31:23,25 54:13 auction 35:12,17,20
91:15 96:5 106:14 57:4,6,7,8,11 83:1 87:17 52:19 53:2,3,4,18,25
arbitrarily 155:3 117:1 132:23 181:2
118:12 119:23 140:4 63:25 94:7 129:16,17
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area 30:4 33:12 34:10 audio 196:3 199:8
apart 158:14 178:23 144:10 193:12 145:11 146:4 166:8
audiotape 170:23 195:16
apologize 12:19 30:16 argument 31:11 assistance 119:9,17 142:7 198:3
51:4 142:8
argumentative 32:15 audiotaped 170:22
appear 173:17 assistant 123:17 152:6
82:22 96:22 115:2
audiotapes 196:4
184:24,25 198:22 assisted 161:22
APPEARANCES 3:1
audit 86:4
Arizona 128:17 assisting 157:12 159:9
appearing 145:4
auditor 14:25
arm 171:13 assume 66:5 73:6
appears 114:17 191:6
August 72:22 80:2,19
armed 176:15,24 188:18 assumes 27:4 30:12 31:17
Apple 129:12,15,19 83:8 86:21 125:11 126:3
188:22 32:25 33:13 35:1,15
applicable 123:14 38:5 40:10 70:18 117:7 authorize 48:6,10 117:3
around 14:21 22:6 124:20
135:12 150:11,14 118:11 135:22 186:4
application 15:19 36:18 authorized 205:9
99:21 193:23 194:24
arrangements 24:10 47:2 auto 123:20 197:8
applied 180:3 97:18 assuming 21:5 64:13 73:5
90:16 133:8 192:20,21 automated 79:10,23,24
apply 27:19 ascertain 183:22 80:8 118:25 119:1
assumption 66:11 97:16
appreciate 201:18 ascertained 35:13,21 automatic 92:11,15
ATP 138:5
ask 8:18,20 9:3,12 12:10 122:20
approval 123:15,20 124:6
17:4 27:14 30:7 38:24 attach 21:11 166:23 automatically 80:10 83:9
124:20 131:12,14
43:24 65:23 68:10 85:6 attached 17:7 55:19 92:12,13,18 118:5
approve 101:12 125:8 87:10 126:1,20 135:23
145:10 73:20 78:6 104:13 automobile 41:5
154:24 157:18,21,24 164:15 166:25 168:10
approved 99:14,17,20 164:8 165:16 173:4 170:12 172:17 176:4 Automotive 23:14 133:25
100:5 101:20 123:19 185:20 192:6,8 197:20 182:5 183:6,17 185:4
198:13 199:24,25 203:1 autonomy 97:18
146:7,9 162:1 186:2,11
approving 100:25 124:3 asked 10:22 88:19 115:1 availability 101:19
attempt 42:25 91:2
129:22 138:2 139:17 159:19 163:2 164:4 available 138:4
approximate 54:3 144:11 172:11 189:19 184:3
approximately 14:16 190:7 Avenue 2:21 3:10,16
attempted 138:14 167:9 93:17 131:1 161:5,11
40:9 87:16 94:22 95:1 asking 9:24 10:1 23:25
APR 100:12 28:25 29:1 74:3 97:15 attempting 121:21 avenues 128:12
113:4 123:7 146:17 154:14,25
April 1:21 2:20 6:1 30:10 award 44:5
147:22 161:9 165:13 attempts 42:16,19,22
31:15 39:18,19 40:17,18 170:25 186:15 189:11 aware 34:8 43:17 44:24
111:7
40:22 41:1,6,14 42:12 194:7 44:25 45:6,11,15 74:10
42:13 51:7 65:4,9 69:19 attend 184:15 75:23 95:17 121:15

169:22 184:2,14 186:5,8 127:1,24 128:5,24 129:6 100:8 102:16 110:25 blank 12:19 117:24
189:18 191:15 204:9 143:24 164:12 166:23 128:25 132:13 141:14 118:16 137:22,23
167:10 168:7 201:6 166:11 185:11 201:5
away 53:22 138:4 160:14 blanks 137:24
204:8
163:13 203:9 Beach 1:20 2:22 3:11 6:1
154:24 161:5,11 believes 44:12 bleeding 171:11
B bearing 99:17 Bell 14:9,10 boat 194:1
B 66:8 71:6 139:1 156:12 because 10:2 27:17,21 B-E-L-L 14:11 body 53:6
156:18 63:22 66:1 78:13,25
below 60:11 122:22 Book 177:20,24
back 21:9 24:20 25:1 80:11,23 82:14,17 83:1
84:14 85:20 87:7,14,21 176:14 borrower 61:7,15 62:22
32:23 72:23 76:10 77:9
78:19 80:17,19 81:3 88:15 93:19 94:23 95:15 BERKLEY 3:16 19:3,6 62:25 85:6 88:7 102:17
83:6 87:9,11,12,18,19 95:19 96:11 97:6,11 70:4 77:6 158:24 164:20 102:23,24,25 103:1
87:20 88:8,14,24 91:12 98:5 103:2,8 106:25 172:6,13 173:6 202:19 112:5,6 113:16,17
91:19,25 94:3 95:25 108:3 111:7 112:24 203:1 114:20,24 115:10 120:3
96:11 97:8 98:3 102:22 125:16 132:2 134:13,16 132:25 133:14 138:3,7
Bernardino 7:24 139:2,4,5,7,8,9,14 140:1
110:25 112:13 116:2 136:24 154:9 155:3
119:15 124:21 125:1 156:17 170:7,19 198:10 besides 100:4 150:7,8,9,11,13,16,21
130:6 131:11 135:4,11 152:9,10 153:11 155:6
Becky 197:17 198:1,5,10 best 11:1,4 14:24 205:24 155:24 156:19 165:21
148:22 152:8 153:23 198:11,12,24 199:9
165:2 190:8 202:22 better 126:15 174:4 190:20,24 191:4,7,8,13
becomes 177:6 191:14,23
back-end 70:5 between 8:3 11:6 14:3
becoming 184:25 20:21 21:24 22:20 24:10 borrower/dealer 120:5
back-up 166:19 26:22 28:14,18 29:24
been 6:5 13:15 14:24 15:1 borrowers 47:3,7 165:25
bad 186:17 43:12 62:9 77:17 80:9 37:23 38:2 39:12 43:4
47:7 54:11 57:5 66:12 borrower's 144:12
badgering 32:16 177:6 86:16 89:13,15 92:12 150:17 152:6
93:14 123:3 132:23 71:18 72:5 74:5 80:12
Baker 152:7 137:20 142:9 143:10 89:11,20 91:1 102:24 Bosley 150:12
146:3 157:13 164:16 103:1,16 112:8 116:21
balance 64:1 87:25 116:24 117:4,11,21 both 68:24 134:10 202:23
128:14 141:18 196:25 165:8,19 171:17 183:23
190:20 193:8 195:23 130:20 140:13 153:20 bottom 57:10 63:2,4
banking 202:9 156:2,14 157:5 188:12 113:10 129:8,11 143:25
before 2:24 6:17,19 17:5 196:20
barely 71:23 45:23 55:21 73:13,22 bought 52:2 114:19
78:2 81:3 94:7,21 beyond 47:16 53:20
Barrientos 152:7 173:6 174:1 181:11 Boulevard 3:4
101:25 114:21 125:5
base 102:6 149:22 164:23 166:5,6 182:12 boxes 107:1
172:22 173:9 183:8 Bianca 142:16 150:16
based 54:5 87:17 branch 15:13
186:19 189:3,6 199:24 152:7,9 155:24 156:8
basic 72:4 100:3 102:6 205:12 breach 17:24 18:2
bid 53:7,11,14
basically 22:23,25 86:12 begged 82:17 break 10:17,23 37:11
92:16 99:23 123:13 bidding 35:12,21 55:7,8 56:4 103:25
beginning 72:7 95:8
124:12 145:14 192:11 big 117:24 104:2 188:20
behalf 6:14,23
basis 169:21 bill 90:4 breakdown 35:13,22
behind 123:2
Bate 94:3 billing 90:10 135:10 BRIAN 1:19 2:19 4:4 6:4
being 14:3 63:22 85:22,23 139:4 6:12 204:22
Bates 4:13,15,16,18,20,22
95:21 96:6,17 98:15
4:24 5:5,6,9,10,12 23:11 bin 91:17 B-R-I-A-N 6:12
99:15,16 101:13,15
23:13,14 55:4,16 56:17
164:18 175:11 177:23 binding 32:2,12 brief 9:15
57:9 64:22 73:16 74:9
182:13 204:9 205:14
76:11 77:12,14,17,25 bird 171:10 bring 54:1 103:19 145:8
78:8 91:19 104:10 belief 141:8 204:7
105:21 107:5 108:17 BISA 145:14 broad 98:5
believe 16:9 19:8 41:23
111:15 112:23 113:2,4 bit 19:15 49:1 100:14 broken 143:6
44:3 78:9 81:9 85:2
116:3 122:9 126:11,14 156:18 167:20 183:20
Brown 172:2,3,11,21 call 19:8,16,18 23:2 63:2 77:19 80:11 82:23 83:25 27:17,24 44:20 50:23
173:12 174:7 176:9,25 65:18 78:13,14,25 84:13 84:14 85:3,23 86:25 53:17 58:10 63:5 65:22
177:24 84:18 85:5 86:12,14 87:2 89:10,21 93:9 96:4 75:17 88:10 99:7,20
90:13 91:12 112:11,18 96:23 104:2 105:13,18 101:3 105:21 164:17
Bruce 150:12
113:10,12 114:16 108:13 109:8 110:1,4 170:18 171:14,16 179:6
building 135:11 119:24 120:6,15 121:1,4 112:23 113:18 114:25 179:19,23 180:2 198:4
123:22,23,24 124:1,2 115:20 121:3 122:2 199:14 201:2
Bundy 176:21,23
125:10 132:1,4,7,22 125:15 137:1,23 142:15
cases 14:2 202:10
burden 202:17 137:2,14,17 138:7,22 143:22 155:9,16 156:18
140:10 142:16 146:22 159:1,4 165:22 167:16 cash 22:24 71:2 123:22
burdensome 202:6 167:19 173:24 175:19 124:10,12,14
148:16,20,21 149:2,6,18
Bureau 181:25 150:6,24 151:13 152:2 175:20 186:1,11 188:22
category 26:16,19 28:6
152:13 154:23 155:8,24 188:24 190:8 194:4
business 1:14,15 2:14,15 30:2,13 33:5,18 34:2
156:24 160:5,7 163:14 197:24 201:25 202:2
38:19 46:8,12 105:14 35:11 36:11 39:11,16
164:4 168:17 169:21 203:10,18
109:9 113:19 116:20 caught 171:17
190:15,16,24 191:2,8 cannot 38:14 50:8,15
117:4,8 125:25 127:6
131:5 133:1 135:11 called 14:2 33:21 53:5 63:19 74:15 109:6 129:2 center 2:21 3:10 12:25
141:7 143:17 144:11,12 57:8 84:5,10 93:11 96:1 134:5 136:25 149:7 14:4 26:10 27:11 45:8
166:21 193:8 101:10 103:11 112:9,15 158:15 159:3 185:25 45:11 47:4,5 48:11,15
113:15 114:2 127:14 200:19 93:17 128:12,16 131:1
button 92:16 160:25 161:1,5,10
131:24 132:5 142:13 can't 10:2 21:9 29:13
buy 99:1 146:22 148:24 149:10 182:25 183:1
38:12 143:12 153:25
149:25 152:6 153:9,23 167:13 182:1 185:19 Central 160:25 182:25
buy-back 80:25
156:8 157:9 160:10
buyer 14:25 56:11 65:21 163:2,9 170:2 174:8 capacity 14:18 32:18 certain 95:25
90:4 92:25 116:8,9,21 190:6 191:4 193:1,2 captured 76:17 certificate 4:14,19 73:25
117:5,11 118:22,24 199:8 74:6,14,23 75:7,15,19
120:10,11 car 19:13 38:4 42:11
caller 78:15 113:11 160:8 75:21 78:17 91:22 94:4
46:23 47:3 48:3 49:16
buyer/dealer 116:11 94:11 204:1 205:8
calling 86:4 169:13 50:5,13 65:9 68:8,16
buyer/dealership 120:13 190:20 191:4 69:3,14 86:18,20 94:9 certified 2:24 143:3 205:6
94:23 95:5,16 97:12
buyer/lessee 90:10 calls 9:19 25:15,20 29:4 certify 205:4 206:1
98:14 103:14 111:11
37:1,15 38:6 42:18 44:6 114:1,3,19,22 132:14
buyers 15:1 48:3 change 11:10 87:16,21
45:21 46:9 54:16 57:14 143:16 159:17 160:11 207:3,4
buyer's 93:1 118:23 65:10 66:17 67:15 68:2 160:20 161:4 162:23
69:5 70:1 71:22,24 163:3,10 164:2 165:7,8 changed 11:12
buying 97:5 81:25 84:25 103:21 168:23 169:5,7 170:5 changes 202:3
105:9 106:5 114:20 171:13,18 174:18
C 129:21 147:20 153:3 177:22 183:13 186:13 changing 90:18
165:14 168:25 174:12 186:20,24 187:12
C 59:2 66:8 characterized 164:24
176:12 178:3 187:24 188:22,24 194:11,16
cab 150:12 197:10 195:6 200:5,9 charge 59:16,17 61:4,11
62:11 66:10 96:7 162:18
calculate 162:17 calm 139:16 card 128:8 131:4 162:20 197:7
CALIFORNIA 1:1,20 came 35:11 84:15 106:17 CarFax 133:20,21,23 charge-back 69:20 94:23
2:1,22 3:5,11,17 6:1 110:12 125:5 160:7 134:5 95:1,4,15 96:3 103:2,11
7:12,15,16,17 46:8,12 can 9:1,11,12 10:17 11:11
46:14,18,24 47:19 48:4 carport 135:13 183:12,21 charged 33:25 59:14
11:22 13:25 27:14 29:14
48:7,11,12,13 53:10 carry 91:11 60:16,19,22 95:25 96:11
31:13 34:23 35:20 37:11
67:14,21 68:8,16 78:15 97:8 128:9,10 171:12
38:10,25 39:1 45:5
78:18 90:12 93:21 cars 46:16 47:8 49:20 181:10,16,17,19
46:19 47:11 50:7,9,12 145:25
103:15 112:7 119:6 50:25 54:7,18 55:8 charge-off 181:22 196:24
131:2 133:25 134:4,7,8 56:21 63:9 65:25 66:5 case 1:7 2:7 5:3 7:1 8:10 196:25 197:5
134:21 135:17,19 136:2 66:11 68:10 70:2 71:23 8:21,22 9:17 10:3 18:4,7
145:15 159:25 161:1 18:8,10,17 19:15 20:13 charges 33:24 35:14,22
73:4 74:13 76:11,25
200:22 205:1,7 36:19 37:7 61:1 63:24

66:1,4 150:13 162:14 198:9,13,17 199:1,3,16 Cologne 147:11 73:1,8,12,17 75:1,24
199:23 201:11,14,17,24 78:10,23 79:8,22,25
Charlene 78:14,21 79:12 Colorado 47:4,5 48:11,15
202:11 203:6,10,12 80:18 81:18 82:1,16
86:10,13
colorful 152:13 83:8,11,16 84:2,12,17
Cindy 172:2,3,11,21
chase 161:8 85:5 86:5,17,22 88:12
173:11 174:7 176:8,25 COM 12:15,16,18,25 89:3,7,12,25 91:2,15,16
chasing 100:14,16 177:24 13:7 26:10 27:14,16 94:8,17 95:3,6,7,8,11,14
citizen 176:6,24 29:18,19,20,23 82:12 95:21 96:15,16,19 97:7
check 84:18
come 27:20 53:7 76:19 97:10,17,25 98:8,9,13
checked 107:1 152:10 citizens 174:8
100:7,11 102:22 118:6 98:19,24 99:11,13 101:5
Cheryl 123:19 131:12,14 city 7:7 204:17 130:6 161:12 192:21 102:12 103:9 105:20,22
131:16,17 199:15 105:23,24 107:13,19
Civic 161:1 183:1
110:12 111:1,11 112:9
Chief 176:13 comes 37:6 101:10 149:22 113:7,22 114:3,21
claim 56:7 95:22
children 170:7 comfort 123:25 115:11 116:12 117:3
claimed 96:6 113:16 120:15,17 121:18 127:3
CHOATE 3:3 9:1,11,21 coming 102:20 127:7 128:3,25 131:3,24
claiming 18:13 96:14
9:24 10:4 19:9,12,17,25 132:1,13 135:1,25 137:3
commencing 2:23
21:8,13,17,20 22:14 clarification 70:4 138:8 139:25 140:2,4,9
23:19,21,23 24:3 25:6 comment 122:25 140:13,22 141:3,13
25:12,16,22 27:6 28:9 clear 19:7 45:3,5 137:3
202:19 comments 76:21 86:9 142:15,18,20 143:15,18
28:23 29:5,7 30:15,17 144:25 147:1 148:11
30:20 31:18 32:17 33:1 123:14,15,18 124:5,19
clearly 176:15 149:2,25 150:20,24
33:3,21 34:7 35:2,16 124:23 125:5,14 131:12
client 106:6 151:4,17,21 152:1,12,14
37:3,17 38:9,24 39:8 communication 38:8,10 152:18 153:9 154:2,7,23
40:12 41:9 42:3,20 43:2 clients 203:8 143:6 155:11,22,23 156:3,24
43:16,20,24 44:8,23 159:12,15,19,23 162:11
Cliven 176:21,23 communications 20:21
45:1,5,22 46:11 52:21 162:22 163:20,25 164:4
35:25 36:5,12 38:19
54:18 55:10 56:21 57:16 close 51:22 100:17 128:14 164:8 165:3 166:7,11
39:5,7,9,12 180:11
61:14 62:15,17 64:24 150:16 167:24 168:2 169:4
65:12,18 66:6,9,19 67:7 companies 19:5 195:8 171:15 172:10 175:16
67:17 68:4,9,18 69:7 closed 144:11
company 1:5,14 2:5,14 179:15 181:3,9,15 184:9
70:2,7,21 71:21,23,25 closure 77:16 186:1,6,13 189:2,5,8,16
4:11 6:15,24 8:12,15,18
77:9 82:23 87:1,10,23 189:18,22 190:2,3,5
clue 194:1 11:15,18 12:11 13:18
88:4,21 98:23 103:23,25 191:10,11,12,13 192:1,2
14:13,17,21 15:6,9,12
104:4 105:11,17 106:14 coach 127:16 192:3,22 193:6 195:17
15:15 16:11,15,21 17:3
107:16 108:13 110:4 196:11,21 197:18,21
code 17:13 129:8 140:23 17:11,14,23,25 18:4,5,6
115:3 118:13 120:23 198:5,25 201:1
18:10,13,17 19:4,7,11
122:2,5 127:18 129:24 codes 166:10 193:15 19:18,19,22,24 20:2,6 company's 20:17 40:16
130:5 132:18 135:23
collateral 99:24 146:4 20:10,12,17,22,25 21:24 41:5 42:11 44:4 47:1
140:6 141:11 142:24
151:8 152:21 154:6,10 22:7 24:10 25:10 26:3 67:21 80:15 141:8
145:16 147:23 151:2
154:15,21,25 155:9 26:22 27:10 28:15 29:11 145:23 154:13 181:6
153:4 155:18 158:6,10
166:4 29:25 32:3,4,12 34:21
158:21,25 159:4 160:17 compels 153:25
35:11 37:21 39:13 42:17
164:22 165:7,16 166:15 collect 8:8 48:2 98:1 42:23 44:3 46:16,22 complaint 17:25 18:3,10
167:15,17 168:5,11 111:8 128:13 154:9,15 47:7,18,21,24 48:2,6,10 18:17 43:12 50:23 51:2
169:2 170:17,20,25 154:25 189:16 48:24 49:5,9,12,15,18
171:4,24 172:25 173:3 complete 76:7,13 125:21
collecting 35:7 49:13 50:5 49:24 50:4,14,20,24
173:15,21 174:3,14,17 125:24
154:21 51:11,23,25 52:1,6,10
175:19 176:19 177:2,5
52:11,18 53:24 54:14,23 completely 118:9
178:4,16,19,23 181:13 collection 93:24 112:12 55:1,5 56:7,25 57:5,12
181:17,21 182:15,18,20 132:3,5 139:8,10 142:9 compliance 36:20 37:8
57:21 58:5,13 61:3,9,10
183:23,25 184:19,24 143:3 147:14 175:23 66:22
61:19,21,24 62:1,6,10
185:7,12,20 186:5,15 183:12 62:13 63:5,14,20 66:15 complied 192:3
188:2,8 189:10,19 192:7
collections 40:17 89:4 67:1,10,13,14 68:14
193:24 194:5,13,25 comply 66:15 86:3 192:24
69:17,21 70:8,15 71:7
196:2,24 197:12,23 college 48:22 71:12 72:9,12,15,18,21

compound 21:16 37:1 204:5 converted 194:22 court 1:1 2:1 3:4 6:19 7:3
177:2 10:7,8,9,12 11:21 14:2
Continental 64:5 conveyed 189:14
21:9 32:24 34:25 42:5
computer 109:4 118:18
continuation 113:9 118:2 cooperate 141:19 69:24 133:13,15 135:14
187:22 188:6
149:21 147:12 150:17 152:10
concept 118:17 copies 119:4,7,13 153:24 182:23 194:9
continue 120:7 143:4
copy 94:11 104:19 122:18 201:20,25 202:24 203:4
concern 121:2 189:16
143:15,19,22 185:15 courthouse 7:5 113:18
concerns 119:20 CONTINUED 5:1 195:22 201:20 202:13 132:25 160:12,25
continuous 118:3 202:19,23,25 203:2,16 162:23 163:3 164:3
concluded 203:20
203:18 174:10 177:18,23
concluding 2:23 contract 4:12 29:12,15
corner 56:10 110:16 193:21
31:25 47:24 51:14,16
conclusion 27:20 37:2 54:5,7,10,15,24 55:2,15 courthouses 133:2
correct 11:15 23:1,5,18
42:19 44:7 46:10 54:17 56:2,3,6 57:4,13,22,23 24:7,11,17 30:6 34:20 cover 135:15
57:15 66:18 68:3 69:5 58:6,7,9,10,12,14,18 63:22 69:4,11,15,16,21
70:1 71:22,24 76:22 60:1 61:10,16,21 62:21 crabby 127:20
70:16 77:4,6 80:2,3
103:22 62:22,25 63:3,13,18 82:20,24,25 89:9 91:23
crazy 150:9
conduct 168:16 64:7,10 71:16,18 72:4 92:25 93:2 96:16,21,24
73:9,13 76:12 80:16,19 98:16 99:7 112:24 114:9 create 75:15 127:7 128:15
confidential 158:7 81:4 83:6 84:15 87:8,11 114:13 119:17 128:19 145:8 156:9 188:18
confirm 86:1 93:12 87:12,15,19 101:4,18,19 137:6 143:11 146:7,11
created 44:17 75:7
144:12 192:3 101:24 102:4,9,17 123:8 147:3 149:19 152:2,3 109:11 128:8,18,21
124:13,16,18 125:11,15 153:10 155:12 160:16
confusion 19:10 131:3 192:4 200:21
125:17,20 126:1,3,5,8 161:1 163:24 165:6
connected 171:2 128:2 130:10,14,17,18 169:18 170:15 176:16 credit 1:5,14 2:5,14 4:11
130:20 131:21 188:14 179:13,16,17 184:12,13 6:15,23 8:12,15,18
conservatively 193:25 192:14 204:10 11:14,17 12:11 13:16,18
contracted 186:23
consider 76:5 134:20 14:13,17,20 15:6,8,12
contractor 133:1,5,6 corrections 207:3 15:15,18 16:11,15,21,23
174:25
135:14,16 160:13,15 correctly 32:8 17:3,11,14,23,25 18:6
considered 67:13 123:24 163:5,12 178:20 190:2 18:10,13,16 19:4,7,8,16
154:17,19 190:14,15,18,21,23 correspond 76:15 19:17,21,22 20:1,2,3,5,6
considering 106:14 191:4 cost 60:11,16,19 101:7 20:10,12,17,22,25 21:24
22:7 25:10 26:3,22
consigned 23:1 contracts 29:13 30:23 Costa 152:7 27:10,13,15,16 28:15,18
31:6 32:7 46:23 47:6,13
consignment 23:2 costs 33:24 36:19 59:19 29:11 30:22 31:5,20
47:14,17 125:8
59:24 197:4 32:3,4,12 35:2,11,25
consult 10:19 contractual 148:10 36:5,12 37:21,23 38:2
couldn't 69:12 106:25 39:13 40:16 41:5 42:11
consulting 14:1 control 96:19 166:3 117:17 142:1 158:18 42:22 44:3,4 46:16,22
cont 117:22 118:2,5 controlled 79:24 125:10 160:13 163:12 47:1,7,15,18,21,24 48:2
contact 4:16,17 43:9 counsel 3:1 10:19 64:21 48:6,9,24 49:5,9,12,15
conversation 36:2 65:16
81:18,21 82:20 84:21 64:23 172:24 173:1,3 49:24 50:4,14,20,24
90:1 91:1 112:8 114:8
86:9 89:11,13 90:21 203:14 206:2,4 51:11,16,23,25 52:6,10
114:24 118:4,20,21
112:2,5 113:14 121:10 52:18 53:24 54:1,14,23
119:14,16 133:9,10,11 country 202:5
134:9 144:14 149:11 55:1,5 56:6,25 57:3,5,12
136:9,11,12 141:1,21
151:13 156:11 157:11 county 1:2 2:2 7:13,18,20 57:21 58:5,13 60:25
142:3 143:1 144:4,6
159:15 190:4 7:22,24 8:1,3 133:2,15 61:3,9,10,19,20,24 62:1
150:5 152:5 156:2 157:5
182:23 193:18 201:1 62:6,10,12 63:4,14,20
contacted 78:16 141:4 160:9 163:7 169:23
205:2 65:6 66:15 67:1,10,13
195:17 198:4
contacting 85:25 179:3 67:21 68:14 69:17,21
conversations 36:9,15 couple 15:4 77:7 102:8,9 70:7,15 71:7,12 72:9,12
contain 41:24 205:22 37:22 38:2 65:21 68:22 157:2 175:24 203:9 72:15,18,21 73:1,8,12
134:14 153:20 163:19 course 105:13 125:25 73:17 75:1,20,24 78:10
contained 36:22 182:8
170:21 127:6 141:7 143:17 78:23 79:7,21,25 80:15
contents 23:18 24:7,9 80:18 81:18 82:1,16

83:8,11,16 84:12,17 2:16 damages 44:5 64:16 66:13 68:20,22,23
85:5 86:5,17,22 88:12 81:25 83:2,4 84:15,22
cross-examine 105:18 dark 183:4
89:2,7,12,25 91:1,15,16 85:10,25 86:5 87:8,15
94:8,17,21,25 95:3,8,10 crossing 66:3 date 14:14 51:9,19 58:2 87:19 95:22 98:6,20
95:11 96:4,14,15,19 71:15 74:19,22 76:3 99:4 100:10 102:24,25
CS 90:3
97:10,17,22,25 98:8,13 91:6 92:8,9 93:25 103:2,3,4,7,17,18
98:18 99:11,14,19,21 CSR 1:24 206:12 109:13 110:15 118:25 105:16 106:1,4 107:4,25
101:5,8,21 103:7,13,19 126:2,4,7 128:2,25 108:1,25 109:7 113:15
105:22,24 106:3,10,17 cue 102:12 114:1,2,4,18,20 115:9
129:3 130:10,14,17,18
107:13,19 110:12 111:1 cumulative 32:16 130:20 160:8 167:5 115:22 116:25 117:5,11
111:10 112:9 113:7,22 179:12,13 184:4 196:12 124:2,4,6,8 125:8
113:23 114:2,16,21 cure 52:23 196:17 207:25 134:11,14 139:6,14
115:11 116:12,25 117:3 current 119:3 147:10 166:8 200:15,17
dated 80:2 81:18 91:22
119:25 120:15,17
currently 15:20 16:21 133:13 dealerships 30:24 31:7
121:18 124:18 127:3,7
53:10,20,21 66:2 94:8
128:3,25 130:19 131:3 cursed 139:18 dates 36:24 73:3 140:16
131:24 132:1,13 135:1 dealership's 30:24 31:7
135:25 137:3 138:8 custody 9:25 DAVID 3:16 171:11,17 31:22 99:5 105:16 117:1
171:19,25 172:20
139:25 140:2,4,9,13,22 custom 88:6 145:23 dealing 27:21
141:2,8 142:15,18,20 154:13 165:24 167:24 day 33:7,11 77:3 84:6
143:9,15,18 145:23 91:7 120:2 127:19 deals 28:19,21
147:1 148:11 149:2,25 customary 66:2 114:4 133:17 138:20 139:24
146:2 154:16 162:21 death 140:1 171:11
150:20,24 151:4,17,21 141:17 142:2 144:16
152:1,12,14,18 153:9,20 customer 13:12 15:2 146:5,21 151:23 153:24 debt 90:16,19 137:12
154:2,7,13,23 155:11,22 27:23,24 28:2,11,16,19 163:7,8 174:11 177:17
155:23 156:3,24 157:5 December 86:7,16,21
29:9 38:16 39:18 40:17 186:17 191:1 204:15
88:11,12 89:6,10,12,16
159:9,12,15,19,23 40:21 47:15 63:22 66:3 206:8
90:3 91:3,5 123:12
162:10,22 163:1,20,25 68:23 76:2,6,16,18,20 days 40:4 102:8 116:7 184:3,4,8,12
164:4,8 165:2,19,21,24 76:25 78:13,16,17 89:14 120:10 150:18 203:14
166:11 167:3,6,22,24 90:9,21 91:5,9,11,12 decide 102:7 111:1
203:15
168:1,17 169:4,14 170:2 93:16 99:3 102:15 103:3
170:22 171:15 172:10 db@severson.com 3:19 decided 84:12 140:2
103:5,8 105:4 108:23
174:18 175:10,16,21 109:1,2 110:17 111:8 decides 102:25 103:4
deal 19:13 28:2,5,7,10
179:15 180:4,9,17,19 113:14 118:6 121:2,4,9 104:23 124:3 192:14 decision 100:5 102:6
181:3,9,10,15,16,21 123:3,22 124:9,14
182:8,10,14 184:9 185:4 dealer 19:16 27:13,15,16 116:20 117:4,8 123:18
125:18 130:23 131:21 131:11 135:2
186:23 189:2,5,8,16,18 132:6 137:16 138:25 28:18 47:15 59:20,21
189:22 190:3 191:10,13 139:18 141:18 142:2,5,6 78:14,15,19 79:1 80:5 decisions 38:20
192:10,22 193:2 196:11 142:10,14 143:2,5 144:3 80:10,12,14 81:2,3
196:21 197:18,21 198:5 86:13 88:9,15 98:3 declaration 185:4,5,7,21
145:1,7 147:19 148:4 185:24 186:2
200:25 201:1 149:12 156:16 166:8 108:10,15 111:14,22
187:13 195:10 198:20 112:14 113:11,17,19 declare 204:3,5,9
credited 64:4
116:9,21 117:1 119:4,6
creditor 56:13 102:20 customers 46:23 153:17 119:7,11 120:4,5,11 decline 109:2
175:11,23,24 123:7,8 129:15 131:17
credits 87:23 99:15 Dedicated 33:17 36:13
customer's 91:10 100:4 131:18,19,20 140:23 132:22 133:6 135:8,18
Credit's 35:7 39:17 40:25 106:20 108:5 125:19 Dealer/participant 136:1 144:7 146:14,23
41:13 168:16 146:3 129:12 152:21 157:6,9,18,24
criminals 150:11 159:13 161:17,19,20,23
cut 166:9 dealers 14:4 53:5 161:24 162:11,18 163:5
Cross-Complainant 1:12 dealer's 108:3 180:23 186:19,21 187:1
2:12 D 187:2 190:20 192:11
dealership 22:21,24 193:8 201:8
cross-complaint 43:11 dad 152:8
26:23 32:7,10 37:18
daily 169:21 42:11 51:15,17 53:6,13 defaults 15:2
Cross-Defendant 17:3
54:1,11,12 57:25 58:3,6 defendant 3:14 8:13
Cross-Defendants 1:16 damaged 44:4 58:7,9,12 59:15 61:17

Defendants 1:9 2:9 determine 21:23 62:24 43:13 46:6 166:14 59:18 68:19 74:3,8
63:19 81:20 82:19 97:23 174:24 199:14 202:15 77:23 91:15 102:10
deficiency 54:2 70:16,19
98:1 100:1 129:18 104:15,17,23 110:21
128:13 discrepant 92:1,12,14
159:20,23 166:19 143:14 184:12 201:7
definition 59:25 discuss 25:2 45:19 136:24
determined 99:11 100:21 does 1:8 2:8 12:18 24:23
138:5,7 153:6 159:5
delinquent 111:9 120:16 134:23 136:3 27:18 29:9 30:13,22
191:6
197:2 31:20 32:11 35:2 44:3
demand 73:8,12 80:18 discussed 44:18 45:23 46:16,22 47:2,5,18,21
83:11,16 86:17 132:14 determines 98:19,25
46:4 47:24 48:2,6,10 62:20
101:5,15
demonstration 174:3 64:1,14 68:7 79:7 80:7
discussing 45:4 91:2
determining 62:4,22 81:1,17,22 82:1 84:20
DENNIS 3:3 84:17 discussion 66:3,12 159:6 86:11 87:11 90:8,25
department 4:22 8:19,21 168:13 201:23 203:11 92:24 97:17,22,25 98:8
deterrent 188:15
9:4,15 10:1 13:10,11,12 102:17 106:23 108:7,14
discussions 106:13
26:5,6,7,9 27:22 28:11 diamond 194:8 109:7 112:1,14 113:13
28:12 29:19 75:9 81:24 Diversity 50:2 114:15,24 115:8 116:5
dictate 109:8,9
82:2,3,5,6,10,19 108:23 117:13,24 122:23 123:5
Divine 15:24,25 127:1,3,6,24 128:10
119:21,25 121:1,3 143:7 didn't 13:6 22:14 25:12
184:10 187:14 200:12 27:14 29:22 30:7 40:8 D-I-V-I-N-E 16:1 129:5,9 131:21 134:3
200:16,23 65:3 85:5 103:13,19 135:9 136:21 137:15,18
119:11 140:12 151:7 division 16:20,21,23,24 138:24 139:1,3 141:12
departments 82:8 161:3,9,14 167:6 169:20 142:1 144:8 146:10
divulge 158:11
depending 76:21 83:5 174:16 195:21 199:13 147:9 149:8,13 155:11
199:19 203:1 DMC 137:10,11,12,13 165:24 170:17 173:17
depends 37:10 148:15 175:10,15 176:19 187:4
Diego 7:18 201:1
Deponent 207:25 DMV 30:10,23 31:14,21 187:8,9,20,22 188:5,17
difference 11:6 43:20 32:5,8,14 36:25 37:10 190:13
depose 172:11 177:14 97:8 156:14 188:12 37:14,19,24 38:4 78:15 doesn't 22:24 43:20 62:24
deposition 1:19 2:19 4:10 differences 188:16 84:10,13 91:9 119:4,8 69:17 80:14 89:11 91:18
6:17 8:20 9:3,16 10:10 134:2,4 184:2,11 200:18 101:1 102:21 142:11
10:17 12:1,4 17:1 18:24 different 14:18 19:5 150:7,15 167:17 188:3
27:18 45:9 67:22 76:24 document 17:8 23:16
26:13 44:19 45:19 48:16 24:6 28:24 45:10 55:15 199:16
56:1 74:8,10 104:4 82:7 93:23 109:7 112:25
125:6 142:12 170:23 55:21,23,25 56:15,16,18 doing 86:4 90:22 96:25
157:23 174:2 182:13 56:19 58:25 63:20,21
195:25 196:4,6,8 201:18 173:15 102:2 118:3 124:2 193:8
64:18,19,24 65:2,14
201:21 202:1 203:2,16 direct 51:25 126:19 66:1 67:25 68:9 69:6 dollar 58:16 63:6,9,13
203:20 205:11,15 207:3 70:9 73:22 74:9 94:3
directing 64:21 65:13 dollars 145:11
describe 24:23 54:7 84:21 105:6,10,16,22 106:3,10
106:17,20,25 107:8,9,10 done 29:16 32:8,9 83:4,5
described 102:18 direction 205:21 107:14,20,22,23 108:2,5 85:9 167:20 193:4
describing 105:3 108:11,18,20 109:10 197:13 202:8,9 203:3
directly 157:11
110:2,13,23 112:24 don't 7:23,25 8:9 14:14
description 4:9 5:2 170:5 disclosed 43:12 177:22 113:3,6 120:22 125:21 19:23,25 25:23 32:18
designation 57:17 137:16 125:23,24 127:11,14,24 41:16 43:21 45:22,23
disclosure 77:1
181:12 182:12 128:5,7,24 130:9 131:7 51:1 54:20 58:16 60:2,4
discounter 15:1 133:13 165:15 166:22 62:21 63:10 65:12 67:11
designed 177:7,8,9 176:17
discounters 15:2 67:23 70:23 71:15 72:1
detail 114:23 documentary 59:6,9,11 73:3,6 77:5 81:5 82:6,13
discounting 29:17,20,23 59:13,14,25 60:23 61:4 88:22,23 90:2 93:6 96:3
detailed 142:3 47:14 63:2 61:12 62:7 96:4,5,9 97:15 99:21,22
details 164:9 discover 102:11 100:9 101:20 102:3
documentation 166:19 104:18 107:17 109:8,9
determination 102:1 discoverable 65:21 115:5 documents 9:25 11:25 113:3 116:1,18 117:10
114:12 120:19 134:18
discovery 8:25 9:10 12:7 12:3,5,6,9 23:19,24 24:1 118:13,14 122:2,4,17
167:13
21:7,16 22:2 25:4 41:24 36:21,23 37:9 51:3 124:7 125:2 127:5,16,21

128:23 129:2,10 131:15 Eastern 89:19 ends 142:19 eventually 80:25 102:22
135:3 136:6 140:21,24
Easy 127:18 enforce 54:9 ever 6:17,19 16:10 55:1
144:23,25 145:16
60:25 70:21 110:21
146:19 148:5,9,13 E-Atlas 93:12,15 enforces 29:2
115:16,19 121:18
153:18,22,25 157:15,17
effect 39:18 40:17,22 41:1 enlist 142:13 140:14,18,21 141:3
158:25 160:18,22 161:2
41:6,14 42:12 179:9 151:16,20 164:8 172:21
161:19 166:2,8,9 168:6 enough 51:5
202:14 205:9 173:9 174:20 177:16,20
169:22 170:1,8 171:4,5
ensure 31:8,24 32:8,9 178:6,9,12,16 182:22
171:6,25 173:7 177:15 effectuate 58:8
45:16 85:22 99:5 117:2 183:8,23 187:12 189:22
179:24 181:25 182:19
effort 164:4 165:21 167:25 181:5 190:3 191:22 192:2
183:2 184:20 185:15,16
192:23 193:19 194:5,15,18,21
186:21 188:23 189:1,7 efforts 112:12 142:9 194:25 195:12 196:11
191:20 192:11 193:12 ensured 45:18 46:3
either 57:1 68:12 76:22 197:7 200:22
193:17,18 194:1 195:15
196:6 197:9,19,22 198:1 100:1 128:13 131:14 enter 46:20,22 47:2 every 18:23 29:19 45:12
198:6,9,10 199:2,5,10 142:10 145:1,6,7 152:10 201:24 45:13 74:4 104:7 109:6
199:12,17,23,25 200:7 156:17 161:6 180:2,22 203:3
entering 97:18
200:24 202:17 203:17 electronically 202:23
entire 30:4 53:12 58:18 everybody 90:23 141:14
door 144:9 electronics 194:11 123:6 143:13 163:7,8 164:23 165:7
down 37:11 60:6 64:18 184:6 194:6 everything 134:7 146:2
elicit 177:7
66:8 71:2 97:5 99:1 entitled 11:1 55:15 193:4 197:4
102:2 114:23 117:19 Elite 133:25 132:13 evidence 8:25 9:10 21:7
139:16 143:6 161:8 else 9:16 13:2 47:10 76:16 entitling 44:5 21:16 22:3 25:5 65:7
draw 177:9 90:20 123:5 146:2 69:18,25 70:12 158:7
163:15 178:24 entity 1:14,15 2:14,15 166:14
drawing 12:19 177:5 70:5 100:20 186:23
email 121:7 136:14,15,19 evidencing 36:23 37:9
drawn 109:23 110:7 136:22,24 137:1 171:10 entries 60:7 157:2 160:3
171:14,16 exact 8:9 14:14 41:16
drew 110:10 entry 79:2,8,10,19,21,23 51:9,19 58:2,16 63:6,9
emailed 22:6 79:12 80:4,7,8 81:14,17 83:19 71:15 73:3 76:3 81:7
drive 150:11,14 161:1
83:22 85:11 86:8 93:6 82:13 88:1,22,23 96:2
183:1 emails 5:4,6 170:4,14 111:13 113:6 116:13 110:15 160:22 161:2
driven 150:13 172:14 119:22 120:1 125:2,3 189:11,12
Empire 8:4 193:7 126:3 131:23 132:16,21
driver 150:13 exactly 112:3 147:5
133:16,17 143:25 144:2
driveway 66:11 employed 105:15 197:21 144:17,20,24 146:5,20 169:17 202:12
driving 150:18 152:9 employee 78:22 89:22 Equal 175:22 examination 4:5 6:8
90:17 111:22 122:23 184:25 205:19
due 35:13,21 111:8 116:8 131:17 148:6 175:15 equity 123:12,13
119:13 120:10 149:11 180:22 206:2,3 examined 6:6 205:14
ERRATA 207:1
181:20 example 154:21
employees 15:20 43:9
ESQ 3:9,15,16
duly 6:5 205:6,15 45:15,18 48:14 179:15 Excellence 45:8,12
180:3,6,9,17,20,21 essentially 59:17 156:15
during 113:18 133:1 except 30:4 196:24 204:6
141:1 143:1 144:12 employer 123:1,2 estimate 11:5,6 50:7
176:25 exception 203:6
employing 179:22 et 1:15 2:15
duties 13:7,22,24 202:1 exclusive 38:9
employment 133:3 even 29:22 38:20 79:12
duty 30:9,14,22 144:13 88:7 101:25 114:16,21 excuse 201:17
125:2 166:9 200:24 execute 116:24 202:21
encompasses 47:16
E 203:8
encumbrances 64:12 executed 28:17,24 54:10
each 32:17 45:12 104:23 evening 132:24 107:2 108:3 192:16
109:6 159:10 end 127:1,2 136:21 137:1 196:22 204:15
event 105:7
earlier 82:14 192:10 endorsements 36:24 executing 61:16
events 43:10 179:9

exhausted 111:7 128:12 fact 11:11,12 109:15 fees 33:24 36:19 37:6 92:9 97:16 104:19 105:1
142:10 143:5 146:3 115:4 126:4 158:19 145:24 105:20 115:8 125:3,13
197:3 160:20,24 170:14 125:22 126:3 152:22
183:21 196:3 felt 126:19 160:5,7 165:4 167:7
exhibit 4:10,12,14,16,17
FERNAU 1:19 2:19 4:4 185:16
4:19,22,23 5:3,4,6,7,8 facts 18:16 21:5 27:5
5:10,11,13 17:1,6 21:12 30:12 31:17 32:25 33:13 6:4,12 104:5 202:1,4,20 five 50:9,11,16,18 196:3
55:5,14,18 56:1 57:22 35:1,15,20 38:5 40:10 204:22
five-two 173:24
58:11,15,19 61:22 63:15 70:18 117:7 118:11 F-E-R-N-A-U 6:13
63:18 68:1 73:17,19 135:22 186:4 193:23 fixed 59:18,22
74:10 75:16 78:3,9 79:9 194:24 Fernau's 202:20
85:1 91:19,25 102:16 flip 23:17 112:17 119:15
Failing 202:16 few 14:4 135:13 142:17 125:1
104:10,12 105:1 110:14 150:14,17
110:25 129:4 131:11 failure 95:4 flipping 91:25
164:12,14 165:10,11 FF 146:10
fair 51:5 175:21 floor 21:6
166:24 167:12 168:7,9 FF290 145:5
170:9,11 172:14,15 fairly 164:24 flooring 21:3,19,21,23
176:3 182:2,3,4,7 183:3 field 14:3 22:11,12,17,19,20 23:5
183:5,14,16 190:8 falls 19:12
fifteen 37:4 24:17 25:2,11,14 26:5
exhibits 4:8 5:1 78:5 familiar 18:1,3,12 104:15 27:17 30:5
104:17 107:9 176:9,11 fifty 31:21
130:4 172:16 flow 125:10
187:5 figure 60:11
existed 186:19 195:21 Flower 160:12,21 163:11
fantastic 152:13 filed 18:4,5,6,10 50:24
exited 177:17 fluctuate 88:1
far 19:25 41:24 44:20 finance 23:4,6,14 27:25
expected 73:11 74:5 fly 184:15
46:16,19 51:11,23 66:8
expecting 124:14 fast 92:17 71:8,13 96:19 108:23,24 FMCC 4:13,15,16,20
Expedition 18:20 19:1 financed 52:7,12,15 59:3 23:11,13 55:16,17 56:22
fault 139:16
33:20 56:23 57:1 71:5 74:9
favor 124:2 financial 13:21,22 14:12 76:4,12 78:1 104:10
Experian 5:10 181:10,15 15:21 16:3 46:20,23 108:18 116:22 117:6
182:8,9 fax 91:6,7,8,9,13 134:15 47:2,6 67:1,14 97:18 120:14 125:2 155:24,25
134:17 184:8,12 200:25
experience 113:21,24 201:2 financially 206:4 FMCC000106-
115:16 123:21 FMCC000120 4:18
faxed 91:16 financing 22:22 24:10,13
expired 52:24 24:16,18,21 41:6 47:16 FMCC000184 57:10
FBI 174:17 49:16 50:21
explain 74:13 89:10 93:9 FMCC000190 4:20
142:15 186:1,11 FC 83:25 84:3 find 69:12 70:13 74:6
76:9 79:13 89:21 105:17 FMCC000197 4:21
explained 91:5 125:4 FCKXC11 89:22
119:7 121:3 126:19 fob 188:21,24 194:3,19
extended 149:11,13,14 FCM 84:1 130:1 135:15 145:9
150:18 191:5 201:5 focus 27:19
extension 91:13 123:9 February 74:24 75:16,20
191:7 79:2 91:22 122:7,14 finder's 144:17 145:11,13 focusing 27:17
124:17,22 133:13 134:1 145:19,24 146:4,6,9,10
extensions 123:9,10 follow 80:24 81:25 82:19
189:6 146:17,24 150:9 154:3,5 83:1,3 165:23 175:16,22
extent 29:3 30:16 38:7 federal 10:7 67:9 154:9,11 157:13 159:10 179:3,16 181:7
65:18 137:2 172:23 161:20,21,23,25 162:1,3
173:1,3 fee 58:25 59:6,9,11,13,14 162:13 163:16,17 followed 45:20
59:25 60:23 61:4,12
extremely 95:20 finding 145:12 following 86:1 88:15
62:7 144:18 145:11,13
150:23
extremist 176:24 145:19 146:4,7,9,10,18 fire 171:13
146:24 150:9 154:4,5,9 follows 6:6 165:21
154:12 157:13 159:10 firm 38:10
F follow-up 32:9,10 80:11
161:20,21,23,25 162:1,3 first 6:5 15:2,11,12,14 81:23,24 82:3 86:8
Face 177:20,24 162:12,13 163:16,17 53:22 58:24 72:25 73:10 91:13,17 121:1
feel 100:14 143:6 77:22 79:19 89:16 92:7

font 36:21 37:8 105:9,20,22,23,24 106:3 40:11 65:10 105:8 146:23 150:24,25 151:5
106:10,11,16 107:13,19 109:14 129:20 147:20 152:2,13,19 154:10
Fontana 160:16
110:12 111:1,10,24 165:14 166:16 168:25 155:17,22 158:14,24
force 81:3 88:8 205:8 112:9 113:7,11,21,23 170:16 173:14 178:2 159:12 162:18 163:21
114:2,15 115:10 116:11 182:11 187:24 188:7 163:23 164:1 168:13,17
forcing 88:13 116:25 117:3 119:5,25 197:10 170:14 171:11 172:5,20
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3:11 6:1 93:17 131:1
impossible 89:7 163:1 190:3 191:13
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informant 157:8,10,13,14
hypothetical 86:25 168:4 improper 86:24 115:3
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history 4:16,17 76:2,6,12 inadvertently 163:15 informants 35:7 36:1
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incentive 95:22 114:22 115:5,10,21,23
hold 88:13 160:13 163:13 identification 17:6 36:22 131:15 133:21,22 134:9
195:8 55:18 73:19 78:5 104:12 incentives 95:20 96:6 135:8,9 136:4,23 137:6
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140:1,10,13,19,25
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home 139:4,5 144:10

153:6 155:4,7,9 157:21 interjected 193:4 issue 116:9,11,22 117:5 152:13,15,19,23 153:1,7
158:24 163:5 164:1 117:14 120:14,16 153:21,23 154:2,8
internally 19:15
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interpreting 17:13 issues 41:14,25 42:12 171:3,20 174:20 177:1
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Itemization 59:3 66:7
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items 63:1 76:19 192:4
27:14,16 29:20,22 48:14 10:4 17:18 19:9,12,17
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48:18 19:25 21:8,13,17,20
112:11
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22:25 26:18 28:24,25
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30:24 31:23 33:21 38:16
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154:23 158:7 162:6 40:12 41:9 42:3,20 43:2
60:10,15 62:18 68:12
inputted 115:22 120:3 188:20 193:2 200:18 43:16,20,24 44:8,23
73:25 79:3 80:2 83:5
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54:18 55:10 56:21 57:16
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inside 195:6 61:14 62:15,17 64:24
192:4,18 102:19,21 108:3,9 109:1
65:12,18 66:6,9,19 67:7
insinuated 193:2 118:3,22 123:7,11,25
inventorying 191:23 67:17 68:4,9,18 69:7
125:24 127:15,19 133:8
installed 34:4 105:5 70:2,7,21 71:21,23,25
investigate 15:17 133:21 134:16 137:14
106:24 108:8,9 77:9 82:23 87:1,10,23
138:18 141:7 146:22
investigation 145:15 88:4,21 98:23 103:23,25
instance 133:7 147:14 149:20 158:9,16
104:4 105:11,17 106:14
investigations 132:3 158:19 164:18,24
instances 113:25 131:20 107:16 108:13 110:4
167:11,15,17 177:7,8
investigator 14:25 15:16 115:3 118:13 120:23
instead 88:13 134:7 183:4,22 185:11 196:3
145:21 146:1 151:21 122:2,5 127:18 129:24
142:20 198:14 201:5,13 202:9
130:5 132:18 135:23
investigators 159:24 202:14,18
institute 89:8 140:6 141:11 142:24
itself 27:17 34:12 56:20 145:16 147:23 151:2
instituted 84:16 86:22 invited 53:7
57:18 64:25 68:10 69:6 153:4 155:18 158:6,10
89:3 invoice 100:1 101:12 71:16 77:16 95:3 108:12 158:21,25 159:4 160:17
institution 22:21 67:2,9 162:8,17 110:3 131:8 165:15 164:22 165:7,16 166:15
101:20 176:18 167:15,17 168:5,11
involved 117:10 159:14
159:15 169:2 170:17,20,25
instrument 54:9 J 171:4,24 172:25 173:3
instruments 27:18 involvement 171:1 173:15,21 174:3,14,17
Jamie 190:20 175:19 176:19 177:2,5
intent 196:15 irrelevant 21:18
Jane 85:11,14 178:4,16,19,23 181:13
intentionally 32:13 154:7 Irvine 3:5,17 14:6,7 15:9 181:17,21 182:15,18,20
133:25 January 77:24 78:10,24 183:23,25 184:19,24
interest 4:12 55:15 95:23 91:12,13,25 92:2 181:20 185:7,12,20 186:5,15
isn't 19:9 22:10 23:17
96:8,12,20 97:1 98:14 job 1:25 13:7,22,24 90:21 188:2,8 189:10,19 192:7
65:2,7 67:24 68:6,12,14
98:19 99:1,12,19,23 193:24 194:5,13,25
69:2 70:12 76:13 77:6 John 113:11
100:9,21,22,24 101:2,7 196:2,24 197:12,23
98:14 138:12,14 149:15
102:3,12,19,20 202:18 198:9,13,17 199:1,3,16
150:19,23 167:2 169:12 Jones 35:25 113:7,9
interested 206:4 141:3,9,12 147:2,7,11 199:23 201:11,14,17,24
169:24 170:2 191:17
147:16 148:24 149:2,10 202:11 203:6,10,12
200:2,5,8
interject 77:7 150:3,24 151:5,14,16,20
judgechoate@yahoo.com klw@severson.com 3:18 knowing 171:19,20 102:8 130:7 133:8

3:6 142:17 144:16 145:4
knew 75:11 78:10 147:2 knowledge 17:11 31:12
148:14 191:1
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185:3 58:22 61:2 68:10 69:9 latter 17:16
knock 144:10 80:21 94:6,20 106:16
judgment 54:2 70:19 law 2:20 3:9 38:10 118:23
166:20 185:2,3 know 8:17,22 13:15 16:4 170:24 204:6
161:5 162:21
16:8 18:9 22:17 25:23 knowledgeable 4:10 6:15
July 72:19 116:2 117:19 26:2,8 27:2,6,7,9 33:9 laws 175:23 181:7
118:20 119:22 120:19 17:2,19,22 18:19,22
34:21 35:2 37:8 40:8 20:9,14,16,20,24 25:2 lawsuit 25:4 38:7,17 43:3
140:10,14,17 167:6 42:25 43:21 45:12,22,23 26:4,14,21 27:2 29:23 54:5 103:20 139:6 156:3
June 72:8,16 73:2,10 45:24 48:5,9 50:16 51:8 30:3 31:3 33:6,9,19 34:3 156:5,9
53:23 54:18,20 55:23 35:6,10,19,24 36:4,12
jury 174:8 58:2,13,16 59:11 60:2,4 lawyer 38:10 106:15
36:17 37:6,13,22 38:1
just 14:4 15:3 21:9,13 60:9,14 64:24 65:16 38:18 39:4,11,17 40:15 lawyers 38:8,13 106:13
23:23,25 38:24 43:21 67:11,20,22,23 70:21,23 40:20,24 41:12 42:10,15 158:14
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140:10 141:21 151:2,7 89:22 90:2 92:17,19 158:23 141:23 142:4 145:2
152:21 155:3 158:21 93:6 94:2 95:14 96:3 166:13
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131:15,16 132:4,7 134:6
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112:24 113:16 114:3,17
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103:12 112:16 132:15
Linex 62:23 Lojack 4:19 34:5 60:14 133:7 146:12 159:11 112:15 114:8 131:23
60:15,20 61:25 107:11 192:25 132:12,17 133:17 135:4
Lisa 15:24 108:7 109:17,24 110:1 136:7 137:4,8 138:11
MacArthur 3:4 140:14,17 141:2,17
142:2 143:1,9,25 146:5 194:5 month 72:7 115:14 89:2,7,11,25 91:1,15,16
147:6 148:12,14 149:3 133:23 184:5,6 94:8,17 95:6,7,8,10,11
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149:25 151:13,23 95:14,21 96:14,15 97:7
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152:22 153:19 155:21 97:10,17,25 98:8,9,13
86:20 100:8 196:22
156:23 197:18 198:4,25 menus 108:25 98:24 99:11,13 102:12
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mark 17:1 55:14 73:17
message 86:12 91:11 111:10 112:9 113:7,22
78:3 164:12 168:7 Moody 172:20
117:13,18 136:22 149:5 114:15 115:11 116:12
172:14 182:2 183:3,14
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marked 4:9 5:2 17:6 113:6 127:3,7 137:19 124:18 127:3,6 128:3,25
method 181:4
55:18,25 57:22 58:10,14 142:14 166:7 191:19 130:19 131:3,24,25
58:19 61:21 63:15 68:1 middle 10:21 57:18 130:9 132:13 135:1,25 137:3
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72:2 115:5
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matter 101:1 204:4 191:1 167:2,24 168:1 169:4,14
motor 1:5,14 2:5,14 4:11
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95:2 122:19 126:18 72:23 73:4 76:3,6,18,20 oath 55:11 96:18 104:6
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134:21 135:16,19 205:8 207:4
130:6 October 81:14,19 83:14
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178:22
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79:23 80:9,16 81:23 105:11 107:16 110:4
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107:11 108:9 109:1 ownership 186:21
117:24 118:9,12 121:3
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117:15 119:23 122:8
64:10 74:19 76:12 79:5 14:12 15:3,21 27:23,24
123:21 124:12 125:2,21 shorthand 2:25 192:12
80:4 81:20 86:8,12 28:2,11,16,20 29:9
132:17 141:19 144:16 205:6
89:22 91:6,7 93:9,20 36:13 38:16 47:4,5,15
147:7 148:24 156:18
107:11 111:13 112:1,3 48:11,15 78:13 89:14 shortly 91:7
160:3 167:19 171:13,14
112:14 113:12,15 116:6 91:5 118:6 128:12
173:11,24 176:13 show 12:8 68:15 69:18
117:25 118:22 122:8,23 137:16 142:5,14 143:2,5
179:11 183:20 185:6 73:4 77:12 84:24 89:11
125:22 129:8,11 130:13 144:3 145:1 156:16
197:20,24 90:25 91:14,18 95:23
135:10 137:12,22,23 186:19
144:17 146:6 148:24 seeing 51:1 140:21 120:1 127:24 134:13
serviced 133:24 142:18 185:14 195:12
149:9 152:1 155:21
seen 17:4,8 55:21 57:1 200:25
156:11 157:8 176:14 services 3:3 16:3 133:25
73:22 122:19 143:14
190:13 162:18 showed 134:8
144:10 171:6 172:21
schedule 72:6 100:12,13 173:9 182:22 183:8 set 35:17 76:7,9 97:1 showing 70:13 119:23
150:17 153:24 205:13 123:11 125:3 138:12,14
Selected 4:20
scheduled 152:10 138:17,18 160:11
sets 112:25
self-evident 173:22 163:10 165:4 171:9,12
school 48:20 several 67:22 87:11 171:16
sell 51:6 53:8,21 196:15
144:13 157:12 159:8,14
scope 25:3 173:6 174:1 shown 161:24
seller 65:22 159:16,20,24 184:7
181:11 182:12
SEVERSON 3:15 shows 56:18 69:2 89:16
Scott 146:6,8,13,14,22 selling 59:4
101:12,13,14 127:13
157:10 186:20 semi-fixed 59:19,23,24 share 114:4 128:1 131:24 181:19
Scott's 146:15 send 23:19,25 30:9,22 she 13:10,13,15 20:1 side 58:23 74:17,20
31:21 32:4,13 101:19 23:24 28:3 64:5,7,20 109:24 110:7 129:11
screen 109:5
102:9 119:8 121:11,16 65:3,4,8,9,23 68:15 130:10,13,22
se 18:21 19:1 33:20 84:2 128:15 137:1 143:22 69:13,18,20 70:14,16,21
sides 68:24
182:1 184:10 196:14 78:16 85:21 91:6 92:20
Seal 171:11,17,19,25
200:22 202:22 92:21 93:1 94:19 99:12 sight 170:7
172:20
119:10 121:20,21
search 74:5 133:12 sending 31:14 78:11 sign 29:13 55:1 135:12,13
140:12 143:20 147:19
144:10 145:15 147:10 121:2 164:9 170:4 202:3,7
148:4,6,8,10 150:6,8,11
sends 200:16,18 150:14,17 151:17,21 signatory 56:25
seasoned 142:14
152:9,10 153:9,10
second 107:5 152:13 senior 145:1 signature 108:4 207:25
155:23,25 156:5,7,20
158:21 171:12 sense 37:3 160:12 163:1,9,11 signatures 56:15,16,18
164:11 165:5 166:12 56:22 57:3
SECSY 60:7 sent 23:4,16,24 36:25 167:3,6,7 169:20 170:5
section 24:16 59:2 66:8 77:23 78:19 80:5 99:22 170:7 174:20,24 175:3,5 signed 185:8 202:23
71:5 108:14 124:24 101:22,24 122:8,13,15 203:16,18
177:16 184:15 186:17
134:15,16 143:15,19 189:18,23 190:4,5 significance 93:25
secure 175:25 160:10 163:10 174:11 196:24 197:20 198:12
security 4:13 34:3,12,16 203:13 signs 203:4
sheet 186:12 207:1,3
34:19,22 35:3 54:9 sentence 117:24 Simple 4:12 55:15
55:16 60:10,16 61:20 Sheridan 56:12 75:3,4
62:11,23 104:23 110:8,9 separate 19:12,13 96:15 93:20 106:22 108:6 simply 31:11 44:19 161:3
140:12 188:13,15,17,22 116:11,21 117:5 120:13 110:20,22 since 10:10 11:9 16:11
120:16 158:13
see 22:8 23:8 50:25 51:18 sheriff 174:18 48:25 66:4 76:11 113:21
58:17,24 59:2,4,6 60:6,7 separately 74:4 113:22,24 121:11
60:12 63:8,21 66:9 Sherrie 172:20 153:10 192:25
September 86:21
74:13,20 77:13 79:3,5,6 she's 85:16 150:10 165:13 single 74:4 180:3 203:3
79:19 81:14 83:19 85:9 series 76:12 173:4,17,19
85:12 89:17 90:6,14 sir 55:13 90:15 104:8
served 21:5 shoot 170:6
93:6 101:11 103:6 sit 11:1
sits 22:25 sovereign 174:8 176:6,23 stands 12:25 118:2 119:3 201:25
123:13 133:5 156:19,21 stipulations 124:15
sitting 10:12,16 161:4 space 117:21 118:8
156:22 190:17
situation 115:4 spaces 135:13 stolen 117:25 140:11
star 109:19,21 165:4,5,22,25 187:12
Sixth 160:12,20 163:11 speak 132:8 188:21,24
start 15:5,9,12 80:10,11
size 36:21 37:8 speaking 30:15 37:3 81:24 114:12 117:24 stolen/lost 119:12
113:9 139:13 142:18
skill 205:24 started 15:8,11,14 139:6
156:25 stop 139:8,10 155:16
190:22
skin 203:12 speaks 56:19 64:24 68:9 stopped 169:13
starting 110:22 126:25
skip 13:10,11 15:3 142:7 69:6 108:12 110:2 131:8
127:18 stopping 155:15
142:8,13 191:7 165:15 176:18
starts 118:21 132:19 story 68:24
small 170:7 special 49:10,13,16 50:3 148:15 149:20
Street 90:5,11 112:7
smog 78:17 specialist 13:21,23 14:13 state 1:1 2:1 4:14 6:10 7:9 135:12 152:7 161:15
15:21 7:11 10:7,9 30:13 66:4
SOC 123:13 stretch 123:22,23,24
specialized 48:25 49:2,6 67:14 68:7 73:25 75:9
sold 51:21 75:13,14,20,25 78:11 124:1,2
49:18,24 50:13,20
106:23 108:7 122:24 strictly 63:1 103:1,5
solve 130:7 specific 27:21 41:17 42:8 129:5 142:1 144:8 147:9
46:19 81:6 122:1 Strongly 138:6
some 10:11 40:6 41:18 149:18 159:25 204:17
53:7 63:21 76:18,20 specifically 49:21 166:7 205:1,7 structures 135:11
77:8 115:5 131:20 140:1 167:5 187:19
stated 35:10 63:14 95:7 STTO3 116:16,17
155:4 156:9,16 170:20 96:10 120:9,24 131:12
specifics 8:9
177:6 188:18 192:12 133:24 139:14,15 stuck 171:10
speculate 156:21 140:11 150:22 151:11
somebody 92:15 186:16 stuff 201:9
188:19 speculation 9:20 25:15,20 174:23 183:12 192:10
37:16 45:21 65:11,19 204:7 subject 21:4
somebody's 84:2
67:16 105:9 129:21 statement 63:8,9 87:13 submission 101:10
someone 114:18 124:23 147:21 153:3 165:14 96:1
145:13,19 146:17 169:1 174:13 178:3 submit 78:17
150:25 163:15 164:1 187:25 197:11 states 31:21,22 53:12
submitted 100:10 101:16
167:22 171:21 193:10 64:10 78:15 90:3,20
spell 6:10 14:10 15:25 168:1
198:24 92:1 112:17 130:9 144:9
spoke 91:4 190:19 197:17 147:10 156:1 176:15 sub-parts 37:4
something 9:25 24:3
90:19 102:22 114:6 spoken 86:14 149:16 stating 70:10 79:10 82:15 subpoena 201:8
166:7 177:8 185:8 100:20 116:23 141:24
Springs 47:4,5 48:11,15 subscribed 206:7
197:23 202:17 142:16 146:24 150:25
ss 205:1 191:3 subsidized 98:15
sometimes 108:25
stamp 23:14 56:17 64:22 status 79:13 86:10,13 subsidizing 96:25 97:2
somewhere 8:3 89:20 91:5
132:3 76:11 77:25 78:8 92:4 substance 36:2,9,15
109:13 111:15 116:3 stayed 138:4 150:5 152:4 160:9
soon 75:11 122:9 127:1 129:6
143:24 163:14 201:6 stenographically 205:20 successfully 85:9
sorry 9:13 11:19 23:12
28:11 39:1 50:8 52:9 stamped 23:11,13 55:5 sticking 174:5 succinctly 175:20
53:19 59:22 62:15 63:16 55:16 73:16 77:12,14,17 still 8:21 9:4 10:13 24:25 such 30:14 117:8,21
77:19 84:1 86:1 104:18 91:6,20 92:8,9 94:3 26:15 35:13,21 55:11 118:8 206:3
117:15 130:11 133:18 104:10 105:21 107:5 79:12 83:11,16 86:16,17
137:21 162:25 192:6 108:17 118:5 127:25 88:7,13 104:6 123:25 sudden 145:3
sort 173:21 128:6,24 160:8 164:13 143:25 150:15 155:19 sue 54:2 155:25
stand 12:18 137:15 188:25 191:24 193:20
sources 93:24 197:20 sued 69:3,13,20 70:10
190:13 119:5 139:14 184:14,20
southern 7:15,17 stipulation 19:20 20:4
standards 86:5 184:21

sufficient 88:16 system 34:4,12 60:10,17 team 85:16,17 116:6,8 41:19 45:1 63:1 64:2,10
60:20 61:20,25 62:11,23 139:21 141:23 142:4 68:24 69:16 77:3 79:10
suggest 143:14
76:15 79:23,24 80:9 145:2 80:23 82:25 83:4 85:14
suggestion 19:3 81:23 83:9,15,22 84:11 88:10 89:9 90:18 94:3
telephone 149:10 157:9
90:23 91:14 92:18 93:11 98:5,6 100:3 101:9,16
suing 150:7 190:17
93:22,23 101:10 102:10 102:11 103:2 113:9
Suite 2:22 3:5,10,17 103:10 104:24 109:25 telephoned 149:9 190:17 118:5,9 119:14 120:9
14:11 144:13 110:8,9 118:4,25 119:1 122:3,5,25 125:6 127:24
tell 17:4 50:9,12 55:11
122:20 125:6,7,9,17 130:20 133:11,20 137:2
summarize 13:25 56:21 65:25 73:4 76:5
140:3,12 141:22 147:14 137:20,25 148:21 156:1
76:11 83:25 84:14 85:3
summary 5:3 171:14,16 148:12 169:24 175:5,10 164:16,19 166:20
85:23 92:7 96:4 104:6
185:2,3 187:7,20,22 188:5,6,13 176:14 184:11,13 190:1
105:1,13 106:25 117:17
188:15,16,17,22,25 191:3,25 192:12,15
SUPERIOR 1:1 2:1 3:4 124:7 125:15 128:6
200:19 194:12 199:3 200:12
133:15 135:14 182:23 137:24 143:12 149:7
202:7,11,15
systems 34:16,19,22 35:3 155:9 163:6 169:4
supervise 15:20 181:3 170:20 171:5 177:13 theft 109:24 188:15,16
137:25
192:23 197:7
178:6,9,12,16 189:8
supervised 14:25 15:1 T telling 96:18 170:4,6,15 their 6:15 27:9 59:18
29:1 45:15 67:4,9 62:23 63:1 67:23 80:11
T 190:17 Temporary 4:23
supervision 205:21 84:11,22 87:21 96:1
T.P 111:13 term 198:10 100:11 103:4 109:1,8,9
supervisor 13:13 15:23 114:19 118:6 123:4
16:4,6 26:8 45:18 82:9 table 23:18 24:7,9 terms 17:13 71:17,20 124:14 129:3 140:3
139:13 72:2,4 99:14,17,24,25 143:5 154:9 158:19
tacked 162:3
supervisors 46:3,7 terrified 152:9 161:12 165:21,22,25
tag 150:16 175:11 187:12 192:13
supplied 17:14 20:12 testified 6:6,19 7:13 8:23 198:21 200:18,19
tail 100:14
180:2 186:14 199:8 10:3 96:17 114:11
take 10:17,23 55:6,8 131:13 178:24 189:10 them 9:7 12:8,11 13:25
supplier 174:18 14:23 30:25 39:23 40:8
87:18 88:24 103:25 189:20 199:16
supply 179:18,21 180:14 104:2 202:16 41:18 57:12 63:1 67:11
testify 6:23 7:3 18:15 80:16,23 88:3,16 90:22
191:22
taken 2:20 6:17 10:10 25:10 26:4 30:3,9 31:13 92:6 94:22 101:17 103:1
support 14:2 164:2 205:12 33:12 34:3,10,15,18,22 103:5,10 109:9 124:3
109:6 134:5 153:25 125:8 128:15 141:4
supporting 102:9 186:12 takeovers 16:16,17
182:1 205:16 145:8 160:14 162:2
suppose 22:15 178:19 takes 200:15 163:13 165:22 168:18
testifying 11:9 172:24
supposed 45:24 74:16 taking 90:11,22 100:11 173:2,4 169:14 170:3 173:9
124:8 179:3,16 183:4 164:6 175:4 177:1 180:3,24
testimony 9:16 11:2,4 182:1 190:16 192:8
187:10 191:18 199:15 12:12 27:15 32:2,3,13
talk 139:13 200:19 193:16 195:10 204:8
sure 14:9 30:8 47:11 83:4 40:1 41:22 42:2 48:16 207:3
talked 118:22,23 123:19 56:4 63:12,17 82:22
91:9 111:16 112:23
138:25 157:10 159:2 180:1 185:23 205:11,18 themselves 61:16 198:24
132:10 136:3 166:1
191:3 205:23
184:10 185:9 193:5 thereafter 91:7 205:20
197:15 talking 38:20,21 72:6 than 13:1 16:17 47:6
77:13 92:8 98:5 113:7 therein 204:7
surrender 161:7 49:20 53:21 74:8 85:1
159:2 165:10 175:18 91:17 98:20 113:6 127:3 thereof 204:5
sustain 158:6 186:14 194:2 197:24 127:7 149:15 170:23
198:7 there's 19:20 20:4 22:10
sustained 9:21 10:4 66:19 173:17,19 191:19
29:19 30:13,14 38:6
68:4 103:23 153:4 169:2 talks 24:9 thank 88:4 104:21 111:21 41:20 57:3,17 60:11
178:4 197:12 182:20 194:13 196:9 65:7,19 69:2,11 70:9
tall 173:11
switches 90:13 201:17 81:7 82:7 84:1 86:7
taller 173:17,19 88:23 92:1 98:14 101:9
sworn 6:5 205:15 that's 10:4 18:23 23:12
tape 196:2 199:8,10,13,17 109:7,19 110:5 116:10
24:3 28:17 30:15 38:9
synopsis 141:24 199:23 120:2,12 122:7 123:7,9

137:22,23,24 146:5 50:3,12,19 51:20 54:17 134:21 trade-in 64:4,8,9,11
149:18 154:5 155:21 55:6 61:8 62:3,5,8 65:16
titling 28:12 31:24 32:5 trailer 150:8
157:2 158:6 173:15 68:21 71:16 75:22 81:7
42:12 66:1 82:17,19
175:9 180:20 191:19 83:14 85:24 86:1,15 trained 180:6,10,18
179:19,22,25 180:2
198:17 200:17,20 87:4 88:16,18,23 89:2,6
89:19,20 92:4 93:3 TL 85:11,19 116:8,14,15 training 48:25 49:2,6,10
thing 20:3 66:10 49:13,16,19,24 50:4,13
95:25 96:2 100:18 120:2,4,9,10
103:13,25 105:6 109:11 50:20 66:21
things 29:13 47:11 64:2 today 6:14 11:1,10 12:1,4
96:16 150:25 175:24 114:13 115:17 116:2 transaction 75:21 123:6
16:12 27:15 32:2,13
202:7 121:14,18,23 122:1
34:11 40:1 41:22 45:20 transactions 179:9
124:6,20 125:14 127:21
think 26:18 65:22 78:3 48:16 63:12 74:8 144:12
128:19,22 132:12,16 transcribed 205:21
115:3 163:16 173:21 152:11 154:23 157:23
136:4 141:1,25 147:1 185:23 193:25
183:4 184:23 transcript 194:6 202:1
150:19 152:14 157:22
third 35:7 108:17 110:13 163:14 167:7 176:25 today's 12:12 203:2 204:4
113:12,15,17,25 114:17 179:9 181:2 186:3,6 transfer 123:12,13
TOE 123:12
115:9 132:25 137:21 189:3 191:22 192:8
138:2,3,5,6,9,12,14,18 193:9 195:9,10 196:12 together 98:11 171:3 transferred 94:7 191:7
139:9 154:14 156:13,15 196:17,20 200:11,14 187:14 trap 156:8
156:20,21,22 164:5 201:18 202:2,14,22
TOL 123:13 travels 202:4
168:2 171:1 179:3 203:3,15 205:12,19
180:11 told 106:15 113:17 tree 171:11
timely 31:24
158:11,14 166:17 169:7
third-parties 49:19 trial 8:15 9:15,16 11:11
Time-out 158:21 169:9,17,19,20 178:19
third-party 36:1 178:20 192:11 198:20 31:11 192:21
times 87:11 113:24
thirsty 10:18 115:13,25 184:7 193:25 Tom 16:7 tried 120:6 139:5,16
160:12 163:11
thirty 203:14,15 timing 102:2 tomorrow 152:11 163:18
trier 115:4
though 29:22 79:12 88:7 title 4:14 13:20,21 15:14 too 19:25 100:17
16:8 20:11 26:2,8 27:9 troubles 145:6
thought 82:18 94:15 95:7 took 54:12 103:9 114:8
29:10 31:1 32:14 36:23 truck 62:23
119:23
threat 140:2 40:25 42:7 47:18,22,25
49:6 57:7 72:10,13,16 tool 93:24 true 22:10 23:17 65:2,7
threatening 167:23 72:19,22,24 73:13,25 67:24 68:6,14 69:2
tools 132:5 142:12 143:5 70:12 96:17 149:15
threats 150:21 164:10 74:3,6,11,14,23 75:4,8
166:12 75:15,19,21 76:1 77:21 top 25:23 51:24 56:10 150:19,23 167:2 169:12
77:23 78:11,18,20,24 58:16,23 59:1 63:10,25 170:2 191:17 192:20,22
three 25:12 50:22 72:25 79:5,9,11,13 80:5,6,9,13 67:11 74:20 81:5,12 200:2,4,5,8 204:6,8,10
110:21 156:12 172:21 80:14,24 81:2,10,13,20 106:20 107:11 110:16 205:22
192:7 81:24 82:1,3 83:2,3,10 116:18 126:12 130:22 truly 32:21
through 1:8 2:8 11:25 83:15 84:18,23,25 85:6 134:15
12:5,6,9 14:23 24:25 85:9,18,19 86:4,8,10,14 truth 55:11 104:7 205:16
total 62:7 63:13 162:4 205:17
30:11 31:15 39:23,25 86:16 87:7 88:8,17 91:9
40:18,22 41:1,6 53:25 91:20,23 92:1,12,14,15 totally 197:3 truthful 122:3 199:4
55:9,17 57:19 94:15 92:18,19,20,21 93:9,12
93:15,19 94:4,6,12,15 toward 71:3 try 150:18 155:24 162:23
101:10 103:10 104:3
119:1 121:25 132:3,4 94:18,19 97:11 98:13 towards 33:19 199:7
143:13 147:14,17 99:8 102:22 110:22 trying 24:25 102:1 115:4
111:11 116:9 117:2 towed 177:23
148:12 155:17 161:12 119:5 124:7 128:13
164:13 166:23 168:5,8 119:9,10,13,17,21,24,25 TP 137:22 139:15 140:3 145:6
168:13 197:14 201:16 120:4,11,18 121:1,20 152:23 153:1 188:20
126:13 134:1,3,6,17,18 TPF 156:10,11,14
tie-in 155:4 191:5
134:20,22,23,25 143:10 TPY 137:18 156:14
tighten 155:19 167:19 143:16,19,20,23 184:10 TTC 138:24
189:9,18 200:3,6,11,21 track 13:6 155:24
time 6:22 10:17 13:6 turn 187:22 188:5
14:18 18:24 22:1 49:23 titled 23:12,14 31:8 86:2 trade 200:2

turned 77:3,5 Unlikely 135:15 using 49:19 79:9 93:25 184:3 187:7,15,23
100:12 150:25 188:20 189:3,17,24
twenty 193:25 unperfected 79:5,9 81:20
190:22 191:5,16,19,24
83:16 86:8 usually 19:11,15 113:18
two 19:5 40:9 49:25 60:6 193:20 196:13 200:2
114:25 132:25
77:4 96:16 107:1 118:8 unsuccessful 123:3
vehicles 22:22 49:3,7,10
133:1 137:24 163:19 utilize 95:22 102:7 108:25
until 16:12 40:8 86:9 53:7 75:9 99:2 151:18
183:15 191:1 125:7 179:24
89:12 102:3 115:16 159:21 200:12,15,17,23
type 7:1 29:13 36:21 139:10 143:2 utilized 93:11 95:20
vehicle's 133:21
121:14 131:13 140:1 99:16
unwilling 141:18
144:24 148:10 utilizing 49:21 102:14 vendor 80:5 148:8
up 24:20 29:14 35:11 45:5
types 16:18 vendors 43:9 47:25
53:8,17,20 59:1 63:1
typically 202:7 80:24 81:25 82:19 83:1
V 179:22,24
83:4 84:4,18 86:1,7 vague 22:1,12 26:17,25 verifiable 155:8
typing 118:6 156:17
88:15 89:6 93:12 100:11 27:4 28:4,7,21 32:16 verification 78:18 202:21
typo 156:20 103:5 109:1 112:13 34:6 37:16 39:6 42:19 202:23 203:4
115:16 123:2,20 127:22 43:1,15 46:9 52:20
U 131:23 132:2 133:16 54:17 61:13 62:14,16 verifications 15:18,19
137:8,19 138:20 139:19 65:11 67:6 68:17 69:25
UCC 36:20 verified 123:20 175:5
145:9,10 148:22 150:13 71:19 97:19 98:21
153:12 155:19 157:3 115:18 121:13,14 127:9 verify 139:5 179:12
unable 142:5 145:9
161:10,14 167:19 140:5 141:10 142:22
unclear 199:21 version 170:23
183:20 189:23 190:22 154:18 175:17 178:14
193:3,16 195:11,13 201:3 versus 19:22 100:2
uncollectible 197:3
198:14
under 10:13 11:9 24:18 VAI 119:3 very 65:19 79:15,19 92:7
updated 90:4,9 92:14 113:10 125:21
55:11 59:2,6 66:1 67:24 Valley 129:12,15,19
81:12 83:25 96:17 98:12 upon 14:2 31:25 53:22 137:3 143:24 146:2
104:6 131:11 145:14 56:7 76:21 83:5 102:6 value 64:14 100:2 192:5 150:16 156:17 170:23
155:19 173:4 205:21 204:7 192:19 184:25 193:9 199:20
underlying 18:15 upset 139:14 Vegas 38:3 119:5 156:6 via 136:22
184:15,21
understand 10:13,19,24 us 13:25 14:23 15:25 50:7 video 177:16
11:2,6,11 29:5 30:17,18 50:9,12 56:21 76:11 vehicle 4:12 18:25 20:18
VIN 18:21 19:1 33:20
31:10 32:20 55:10 96:9 87:20,22 88:3 99:6,15 22:25 27:22,25 28:3
78:17 84:10 170:6
97:15 124:7 149:24 99:22 100:10 101:1,16 29:10 32:14,19 33:7,11
166:2 182:15,17 187:13 101:24 102:9 105:2 33:22,24 34:4 35:8,12 Vincent 96:1 103:10
112:4 113:9 114:5 36:6,13 37:24 39:14
understanding 33:1 violence 167:23
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Brian Fernau Confidential April 5, 2017

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FORD MOTOR CREDIT COMPANY, LLC,

LENORE LUANN ALBERT-SHERIDAN, AND CASE No. 30-2015-

LENORE ALBERT AKA LENORE LUANN

FORD MOTOR CREDIT COMPANY, LLC, A

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1 A I do performance consulting risk management, also 1 A Yes, D-I-V-I-N-E.

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1 MS. WALKER-PROBST: Objection; vague as to time, 1 documents last night?

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1 BY MS. ALBERT: 1 A No.

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1 A Yes. 1 BY MS. ALBERT:

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1 A Yes. 1 third-party informants, including the identity of those

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1 MS. WALKER-PROBST: Objection; misstates his 1 BY MS. ALBERT:

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1 BY MS. ALBERT: 1 A No.

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1 Q Yes. 1 is anywhere in this contract?

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1 of Nevada on the vehicle. 1 title the vehicle?

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1 A I am looking at FMCC 000119. 1 A Yes.

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1 conversation? 1 5, it states that there's a discrepant title.

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1 March 4, 2015? 1 called their Vincent statement.

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1 dealership. 1 Q How do you know the dealership prepared this

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1 dealership with regards to payments on a car where the 1 A I don't know.

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1 Sacramento"? 1 A Yes. If you show that -- on the last entry, same

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