Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-10

Filed 02/16/2006

Page 1 of 2

1 IN THE UNITED STATES DISTRICT COURT

Page i

2 EASTERN DIVISION
3

FOR THE DIS~RICT OF COLORADO

4 CAMILLE MELONAKI S-KURZ,

etc., et al.,
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Plaintiffs,
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Case No. 03-CV-2485

vs.
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(MSK/PAC)

HEARTLAND HOME FINANCE,

8 INC. ,
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9 Defendant.
WEDNESDAY, NOVEMBER 9, 2005

12 - - - - 13

11 THE DEPOSITION OF RYAN COUSINO

14 The videotaped deposition of RYAN COUSINO,
15 called by the Plaintiff for examination pursuant to 16 the Federal Rules of Civil Procedure, taken before 17 me, the undersigned, Darlene Vance, Registered

18 Professional Reporter and Notary Public within and
19 for the State of Ohio, taken at the offices of Cady 20

21 Reporting Services, 1225 Illuminating Building,
22
2 3 C level and, 0 hi 0 , co mm en c i n gat 2: 1 6 p. m., the day

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25 and date above set forth.

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

Document 345-10

Filed 02/16/2006

Page 2 of 2

Page 42

1

Q

So you would call the second-round leads?

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A
Q

Um-hum.
And what kind of information would you try and

get from that individual? What was the purpose
of the conversation?

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MS. NOVAK: Obj ection.
A

From them, at that time? I don't remembe r .

Because I'm kind of going into what I'm doing
right now, and I'm getting them mixed up a

9

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li ttle bi t of how I did it then and how I do it
now, so -- I mean, I would get their income. I
used that pitch sheet that I transferred on to
a 1003.
Q

11
12

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14

I f we could talk a li t tle bi t about your pi tch

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sheet. How did you create that?
A

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I made that up a long time ago; I did it on

Excel.
Q

Did anyone help you put that together?
Someone helped me out, it was a buddy of mine.
He was on a --

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A

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Q

Was it a Heartland Home employee?

A
Q

No.
No?

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A

No, it was on a Sunday. A buddy of mine, one
of those get-togethers, and, hey, print me out

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