Free Motion to Compel - District Court of Colorado - Colorado

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

Document 355-11

Filed 02/23/2006

Page 1 of 4

EXHIBIT J

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

Document 355-11

Filed 02/23/2006

Page 2 of 4

Charles M. Seelig 1/9/2006 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 1

1

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO

2 3

* * *

4 CAMI LLE MELONAKI S - KURZ,

5 et al.,

7 vs. CASE NO. 03-MK-2485
8 HEARTLAND HOME FINANCE, INC.,
9

6 Plaintiffs,
Defendant.

10

* * * 11 Deposition of CHARLES M. SEELIG,

12 Plaintiff herein, called by the Plaintiffs for
13 direct examination pursuant to the Rules of Civil

14 Procedure, taken before me, Kathy S. Wysong, a

15 Notary Public in and for the State of Ohio, at the
16 offices of Mike Mobley Reporting, Inc., 334 South
17 Main Street, Dayton, Ohio, on Monday, January 9,

18 2006, at 12:02 p.m.
19

* * *

20 21 22

23
24

25

Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 355-11

Filed 02/23/2006

Page 3 of 4

Charles M. Seelig 1/9/2006 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 77

1

A.

Local manufacturing.

Honeywell,

2 Johnson's Manufacturing, Siemens Manufacturing,

3 I think International was part of it, and a few 4 of the little smaller plating companies within

5 our area.
6

Q.

Do you - - do you know what court

7 that case was in?
8

A.
Q.

9

10 11
12

A.
Q.

Federal court. Here in Ohio? (Indicating. )
In Dayton?
I don't know.
I

A.

don't know.

When

13 it got to that -- that realm, I understood that

14 they were going after money, they weren't going

15 for cleanup so I couldn't stand to be part of
16 it any longer.

17 They took what I originally tried
18

19

to start, to clean up the water, and they corne in for money and that wasn't me . It would do
no good.
Q.

20 21
22 23
24

And I

think
Yes.

you

said -- did

you

say

that

you
A.
Q.

lost your
Yes.

house dur ing

that time?

Did you ever file for bankruptcy?
Shortly after, yes.

25

A.

Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 355-11

Filed 02/23/2006

Page 4 of 4

Charles M. Seelig 1/9/2006 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 78

1

Q.

And when was that?
I believe it was 2003.

2 3

A.
Q.

And do you remember which

4 bankruptcy court that was in?

5 A. We met in Springfield above the
6 post office. That was about it.

7 Q. Do you remember who your attorney
8 was for that?
9

A.

Some shyster out of Springfield.

10 No, I don It.
11
12
Q.

Okay.

A.

He i S real close to the post
was just the

office. Everything he told us 14 opposite of how it turned out.
13

15 My wife had a stroke that year.
16

My son i s appendix burst.

Many

many things

17 carne to that, but I'm not here to defend the 18 reasons why I went into bankruptcy with you.
19
Q.

Your son -- how many kids do you

20 have?
21
22
A.
Q.

Two.

Two. And are you involved wi th

23 any activities -- or when you were working at

24 Heartland, were you involved wi th any
25 activities that they had?

Paradigm Reporting & Captioning Inc.

612-339-0545