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:
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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, 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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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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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?
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And you understood when you were signing this
23 that you were signing it under penalties of perjury?
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Q
Yeah.
Just to clarify in paragraph 2 where you say
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Paradigm Reporting & Captioning Inc.
612-339-0545