Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-32
Dean Rohrer 1/10/2006

Filed 02/16/2006

Page 1 of 3

Camile 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 CAMILLE MELONAKIS-KURZ,

5 et al.,
7

6 Plaintiffs,
vs.
CASE NO. 03-MK-2485

8 HEARTLAND HOME FINANCE, INC.,

9 Defendant.
10 11

* * *
Deposition of DEAN ROHRER, Plaintiff

12 herein, called by the Plaintiffs for direct
13 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 Tuesday, January 10,

18 2006, at 8:29 a.m.
19

* * *

20
21
22

23
24

25

Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 345-32
Dean Rohrer 1/10/2006

Filed 02/16/2006

Page 2 of 3

Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 47

1 they got it and answer any questions they have.

2 Have them FedEx it back to us, and by that time
3

have an appraisal going at the door.

And then

4 the apprai sal come back in and then submi t the

5 package together wi th the income, W-2 s, any

6 bankruptcy statements, divorce decrees, child
7

decrees for child support, alimony.

Make sure

8 we have a full packet, give it to the
9 processor, and then send it off to the bank.
10
12
Q.

Okay.

Tell me -- you know, you

11 said that at the very beginning you'd sort of
find out what they wanted to accomplish.
How

13 did you go about doing that?
14

A.

Well, the company would gi ve us

15 the leads from telemarketing, from the company

16 they own as a subsidiary, and the telemarketer
1 7 would open the door for us and then we'd follow

18 up with a phone call to see what they wanted to

19 accomplish, how soon they wanted to get it
20 done.
21 22

23
24

-- make getting
because
and you

25

then by as king that, and then a -- get an interest, make sure you're some spread off of it, if not, fees everybody wanted to do it for nothing can do it the easy way or the hard way.
And
Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 345-32
Dean Rohrer 1/10/2006

Filed 02/16/2006

Page 3 of 3

Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 48

1 You can either pay the fees up front and be
2 over wi th it or take -- bump the ra te by one or

3 two points and pay on it for as long as you

4 have the loan.
5

Q.

Now, how did you decide sort of

6 which way to go on that, I mean, in other

7 words, with the spread or with the fees? What
8 would you look at to determine which way the -9 you know, what would either be better for this

10 customer or how to respond to what it was that

11 they wanted in terms of spread or fees?
12
A.

Well, if they didn't like the
If they didn't like the

13
14

fees, they'd tell you.

rate, they'd tell you.
there was any points.

They wanted to know if

15

So then you'd have to

16 figure out how you're going to get the money
1 7 because we average somewhere around thirty-two

18 to thirty-six hundred dollars in fees per loan.
1 9 That's a combination of fees and spread.

20

Q.

And so would you then decide sort

21 of how to put that deal together in terms of
22 what would be appropriate and what the customer

23 would be willing to accept, is that how that
24 worked?
25
A.

Well, we was always told sell the

Paradigm Reporting & Captioning Inc.

612-339-0545