Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-28

Filed 02/16/2006

Page 1 of 4

1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
2 3

Page 1

4 CAMILLE MELONAKIS-KURZ,

etc., et al.,
5

Plaintiffs,
6

Case No. 03-CV-2485

vs.
7

(MSK/PAC)

Heartland Horne Finance,

8 INC. ,
10

9 Defendant.

12 - - - - 13

11 THE DEPOSITION OF BRADLEY REYNOLDS
THURSDAY, NOVEMBER 10, 2005

14 The videotaped deposi tion of BRADLEY
15 REYNOLDS, called by the Defendant for examination 16 pursuant to the Federal Rules of Civil Procedure, 17 taken before me, the undersigned, Darlene Vance,

18 Registered Professional Reporter and Notary Public

19 within and for the State of Ohio, taken at the
20 21 offices of Cady Reporting Services, Inc., 1225 22 23 III umina ting Building, Cleveland, Ohio, commencing 24 25 at 8:09 a.m., the day and date above set forth.

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

Document 345-28

Filed 02/16/2006

Page 2 of 4

Page 87

1

documents on every file, it just particularly
what that client's credit qualified them for.
Q

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3
4

Okay. After you did that, what did you do
after that

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A
Q

After I -After you analyzed the client's application,

what did you do after that?
A

Once I knew I had -- I had them fi t into a

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particular program, we got pre-approval on that
loan and sold the client on that program.
Q

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Who did you get pre-approval from? The bank that we were using at the -- for that

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A

client.
Q

Did most of your loans go through Heartland?
I tried.

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A
Q

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What percentage of your loans went through

Heartland?
A
Q

Again, I mean

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On average.
After banking was open?

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A
Q

After banking was open, what percentage of your
loans wen t through Heartland?

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A
Q

I would hope 75 percent of them.

Before Heartland Banking opened, what

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percentage of your loans went through

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

Document 345-28

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Q

Okay. And when you worked in the Dayton
office, how much time did you spend working
inside the office?

2 3
4

A

Most of the day, because, like I said, at that

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6
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Q

point I had vehicle issues so I was kind of

stuck there.
So you spent the maj ori ty of your time working

inside the Dayton office?
A
Q

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Yes, ye s .
Did you also -- where did you receive your
leads when you worked in the Dayton office?

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A
Q

From Heartland.

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Okay. And what percentage of your leads did
you recei ve from Heartland when you working in
the Dayton office?

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A
Q

I believe all of them.

Okay. I want to talk a little bit about the
brokered loans that you had discussed earlier.

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I understand that before Heartland Banking
opened that you did broker out loans.
A
Q

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Yes.
Okay. When Heartland Banking opened, and you
brokered out loans -- or that's the term that

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was used, let's talk about those loans. I want
to talk about those loans in particular.

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

Document 345-28

Filed 02/16/2006

Page 4 of 4

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Okay. After Heartland Banking opened you

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would still would you still receive a lead
from Heartland Horne Finance?
A
Q

Yes.

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Okay. And then you would take that lead
through the process that you just explained to
me earlier?

A
Q

Urn-hum. Yes.

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Okay. And if underwriting rejected it, then
wha t happened?

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A

We were able to source that through other

companies.
Q

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Okay.

So it had to go through Heartland first;

is that correct?
MR. CARR:
Obj ection,

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17
Q

leading.
You can answer.
Not at the beginning.
A
Q

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When Heartland Banking was opened, did it have
to go through Heartland first?

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A
Q

Not at the beginning.

Okay.

I gue s s I'm not unde r standing what you
The beginning of --

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A

mean not at the beginning.

Well, when banking originally opened, we still

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had options.