Free Reply to Response to Motion - District Court of Colorado - Colorado

Case 1:03-cv-02485-MSK-PAC

Document 367-4

Filed 03/07/2006

Page 1 of 3

Nirit K. Roddy 12/16/2005 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

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Videotaped Deposi tion of NIRIT K. RODDY
Greenbel t, Maryland
F rid a y , Dee e mb e r 1 6 , 2 0 0 5

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8:17 a.m.

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20 Job No. 3-69499

21 Pages 1 - 103
22 Reported by Sara A. Cissin, CSR
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Paradigm Reporting & Captioning Inc.

612-339-0545

Case 1:03-cv-02485-MSK-PAC

Document 367-4

Filed 03/07/2006

Page 2 of 3

Nirit K. Roddy 12/16/2005 Camile Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 89

1

Q

And so when you did tha t Howard let you charge
Is that right?

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a lower amount.
A

He told me to. He told me what to -- like

4 wha t to charge.
5
Q

Was there ever a point where you charged less

6 than wha t he told you?
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A
Q

I don't remember honestly.

How about more than what he told you?
I don't remember ei ther.

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A

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MR. POCKRASS:

I've been told we are able out

11 of tape on this tape, so we need to take a quick break.
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V IDE OG RA P HE R : We are go i n g 0 f f the r e cor d .

13 The time is 11: 45 a.m.

14 (Break taken.)
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VIDEOGRAPHER: This marks the beginning of

16 Tape Number Two. We are back on the record. The time

17 is 11:48 a.m.
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MR. POCKRASS: Mark this.

19 (Roddy Exhibit Number 5 was marked for

20 identification and was attached to the transcript.)
21 BY MR. POCKRASS:
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Q

I'd like you to take a look at Exhibi t 5 and

23 if you look at the bottom of each page there's a number
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there, DEF128 93, and it runs through DEF12 913.

I'd like

25 you to take a look at the ones that are marked DEF12893

Paradigm Reporting & Captioning Inc.

612-339-0545

Case 1:03-cv-02485-MSK-PAC

Document 367-4

Filed 03/07/2006

Page 3 of 3

Nirit K. Roddy 12/16/2005 Camile Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 91

1 realize that would be your old signature but-2 3
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A
Q

Which? I'm sorry.
It's DEF12906.

A

Okay, fine.

Yes, that ls my -- that is

5 definitely me.
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Q

Okay. And then did you also initial DEF12911?
Yeah, I'm sure I did. Yeah, I'm sure I did.

A
Q

Did you have any discussions with Mr. Ross

9 when you completed that Employment Agreement?
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A

I don't remember.

I'm sorry, I barely

remember thi s . So. . . 12 (Roddy Exhibi t Number 6 was marked for

13 identification and was attached to the transcript.)
14 BY MR. POCKRASS:
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Q

If you could take a look at Exhibit 6, is that

16 your signature at the bottom of this?
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A
Q

Yes.
And did you sign this on November 17, 2004?

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A
Q

Yep, I guess I did.
Yes.

It says so.

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Did you read this before you signed it?

A
Q

And you understood when you were signing this

23 that you were signing it under penalties of perjury?
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A
Q

Yeah.
Just to clarify in paragraph 2 where you say

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Paradigm Reporting & Captioning Inc.

612-339-0545