Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-30

Filed 02/16/2006

Page 1 of 4

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

Page 1

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Videotaped Deposi tion of NIRIT K. RODDY
Greenbel t, Maryland

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Friday, December 16, 2005
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 345-30

Filed 02/16/2006

Page 2 of 4

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

Page 89

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Q

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

a lower amount.
A

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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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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. POCKRAS S :

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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VIDEOGRAPHER: We are going off the record.

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 Exhibi t Number 5 was marked for

20 identification and was attached to the transcript.)
21 BY MR. POCKRASS:
22
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, DEF12893, and it runs through DEF12913.

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 345-30

Filed 02/16/2006

Page 3 of 4

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

Page 90

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through 12896.

That's pages 1 to 5 of this, and let me

2 know whether the ini tials in that bottom right are your
3 ini tials, whether you ini tialled that?

4 A Yeah, it looks like my initials.
5 Q Now, on that first page there -6 A Which page?

7 Q 12896.

8 A Okay.
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Q

You see that paragraph 11 iS crossed out?

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Q

Yes.
And do you remember any discussions that

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12 occurred when that paragraph was crossed out?
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Q

No, sorry, I don't remember.
That's okay.

Do you remember Howard Ros s

15 cros sing tha t out?
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Q

No, I don't remember it at all.

Okay.

Going through the rest of the pages

18 from 12897 through 12905, are those your initials on the
19 bottom each of those pages?
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A

Yeah, yeah, I mean I'm pretty sure they are my

21 initials.
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Q

Right.

Did you initial those?

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A

Yeah, I'm sure I did.
I jus t don't remember.

I'm not saying I

didn't.
Q

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Page 13, is that your signature? And I

Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 345-30

Filed 02/16/2006

Page 4 of 4

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 iS 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.

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Q

Did you have any discussions with Mr. Ross

9 when you completed tha t Employment Agreement?
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A

I don't remember.

I'm sorry, I barely

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remember this.

So. . .

12 (Roddy Exhibit 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, ls 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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Q

Yep, I guess I did.
Yes.

It says so.

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Did you read this before you signed it?

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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