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