Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-42

Filed 02/16/2006

Page 1 of 3

EXHIBIT G

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

Document 345-42

Filed 02/16/2006

Page 2 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 03-MK-2485 (pac)
Camile Melonakis-Kurz, individually and on behalf of other similarly situation employees, and other individuals who have consented to join this action,

Plaintiff,
v.
Heartland Horne Finance, Inc.,

Defendant.

AFFIDAVIT OF DONALD FLYNN
I, Donald Flynn, having first been duly sworn upon my oath, state that the following are
true:
1. I am an adult, over the age of 21, and of sound mind. I am competent to testify,

and I have personal knowledge of the facts set forth herein.
2. I am a resident of Ohio. I am an owner and Vice President of Hearland Home

Finance, Inc. ("Heartland"), a mortgage banker and broker. I am familar with the licensing and

training requirements for loan offcers employed by mortgage bankers and mortgage brokers in
Ohio and other states where Heartland does business.
3. In Ohio, loan offcers who broker loans are required to pass a knowledge test
covering federal and state laws and regulations, product knowledge, processing knowledge,

associated math, and ethics. There is also a six-hour per year continuing education requirement

(and a twelve-hour anual requirement for those who broker loans in Kentucky).
4. Ilinois has licensing requirements for loan officers who broker loans that are

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

Document 345-42

Filed 02/16/2006

Page 3 of 3

similar to the Ohio requirements.
5. In Maryland, all loan officers must go though twenty hours of

training within six

months of hire.

FURTHER AFFIANT SA YETH NAUGHT.

I hereby affrm, under the penalties for perjur, that the foregoing representations are true
and correct.

Dated: "L \ \ ') \ (;

STATE OF O\-û
COUNTY OF Cù"\~

)

) SS:
)

Subscribed and sworn to before me, a Notary Public in and for ~)1 County, State of lPl'h'D , this JLday of ~ú.A"l , 2006.

Notary P~
Printed
County of

o 1 r ßJJ
(JMl¿ tl F- ßCkl- KE
, - .14,' Residence: (.IVl ,.I
DARRYL F. BOEHMKE. .
Notary ,PUblic, State of Ohio My Commission .Expires Sept. 27, 2009

My Commission Expires:

Seff 11, 200î

(Recorded in lorain County)