Free Brief in Support of Motion - District Court of Colorado - Colorado

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

Document 339-39

Filed 01/31/2006

Page 1 of 20

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO

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CAMILLE MELONAKIS-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,
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INC. ,

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Defendant.

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f

CC (Q lY

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THE DEPOSITION OF ALFRED SANFORD WEDNESDAY, NOVEMBER 9, 2005

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The videotaped deposi tion of ALFRED SANFORD, called by the Defendant for examination pursuant to

the Federal Rules of Civil Procedure, taken before me, the undersigned, Darlene Vance, Registered

Professional Reporter and Notary Public wi thin and
for the State of Ohio, taken at the offices of Cady
Reporting Services, 1225 Illuminating Building,

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Cleveland, Ohio, commencing at 11:59 a.m., the day
and date above set forth.

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

Document 339-39
Alfred Sanford 11/9/2005

Filed 01/31/2006

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

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Q

What 1S your current employment?
Heartland Home Finance.

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A
Q

And what do you do for Heartland Home Finance?

A
Q

Senior loan officer.
And who 1S your direct supervisor?

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A
Q

My manager 1 s Dary 1 Boehmke.
Now, if i understand it, you have been employed

off and on wi th Heartland Finance over a period
of time.

When was your first employment wi th

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11
A
Q

Heartland Home Finance?

Okay.

I believe it was in 2001.

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And what did you do for them at tha t time?
At that time, I was a -- what we would call a

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telemarketer.
Q

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At what point did you become a loan officer?
In 2002.

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A
Q

I'd like to first start by talking about the

job of loan officer.
A
Q

Had you been a loan

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officer at other companies?

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Yes.
Wha t are the name of some of those other

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A

companies where you've been a loan officer?

Nationwide Mortgage Company 1S the only other

company.
Q

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And when were the dates of your employment wi th

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Alfred Sanford 11/9/2005

Filed 01/31/2006

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Camile Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.

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and sometimes I would leave at maybe 12: 00; and

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then I would come back and then sometime I

would stay until 9:00, 9:00 at night, or 8:00

depending.

But that

those would always

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change in regards to as far as doctor's

appointments.

My wife, she was very will for

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the last three to four years, so I would often
leave work to take her to the hospi tal to her

appointments because she doesn't drive.

So it

10 11 12 13
14
Q

would vary.

On average week -- some weeks, I

might get 30 hours, some weeks I might get 40,

some I may only get 20, depends on what I had
going on in my life at that time.
And wha t, if any, sta tic did Heartland give you

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about these varying hours?
A

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Well, with Judy Engelhart, Miss Judy -- with
Judy, I never had any problems.

The only thing

tha t she required me, when I was there, to do
my job.
And she was very accommodating as far
I only have one eye,

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as my medical reasons.

I'm a disabled veteran, so I had a lot of

I

had to go to a lot of appointments for my eye

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during the weeks and so forth.
her to the doctor.

My wife has a

very serious disease, so I used to have to take
Plus she had a coupl e

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team at any time at Heartland?
A
Q

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Yes.
And when, if ever, did you ever see him on

Saturday?
MS. FISHER:
Obj ect to the

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to the extent it calls for specula tion.

You

can go ahead and answer.
MR. CARR:

He can

testify to what he saw.
A

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Mr. Ziemak? Never.
when I was there.

Not to my knowl edge, not

Q

You mentioned a moment ago how Judy Engelhart
was very accommoda ting wi th respect to your

flexible hours and your si tuation.
A
Q

15

Yes.
You didn't comment on Daryl Boehmke and how he
has reacted to it?

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A

Oh, Daryl? Daryl -- well, really, right now,
you know, I told him I had things to do, you
know, they accommodate me, you know.

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Q

Did either one of them at any time ever say to you -- what, if anything, did they say to you
about working 40 hours?

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A

Well, with Daryl, it's a standing

it's a

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standing rule in the office where we work at

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where I work at now.

It's a different

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location.

Where if you have 40 hours -- if you
On

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4

have -- like, I'll give you a good example.

Thursdays, if you've got 38 hours in, you only
work two hours on Friday, and that's it.
You

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Q

have to leave.
of the office.

He automatically puts you out

Well, from -- say, from 2002 forward, was there
any other policy besides that one in terms of

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A
Q

working hours?
40 hours a week.

40 hours a week, as 1n

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A

You know, they wanted to you work 40 hours a

week.
Q

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Did they want you to work more than 40 hours a

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A
Q

week?
No, it was always 40 hours a week.

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Okay.

Talking about other people on Saturday,

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did you ever -- was Sharon Fleck part of your

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A
Q

group? She was not, was she? No. No, she was on another floor.
Would you have visi ted other floors on a

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A

Saturday to see what was going on?

Sometimes, because the majority of the time she

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have -- they didn't have keys to get into the

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to.
Q

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So you can comment on your own observations.

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A

Basically, I was always the one that was there
at night.

Usually it was just me.

I'm the one

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8
Q

that was usually there at night, because they
had to lock the doors and I was basically the
only one that was allowed a key.

So approximately what time, 1n your experience,

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did you see the other loan officers leave in
the evening?
A

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I would say maybe 5:00, 6:00 -- 6:00 at the

latest.

It would vary.

Some loan officers may
They may

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stay later because they got in later.

have had appointments

do things in the day,

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or they may have what we call a closing going
on that night, so you stay there, you wait for

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Q

your closing.

But other than that, you leave.

What about Fridays, did people stay later or
leave earlier on Friday afternoon?

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A

Friday was normally a half a day.

A hal f a

day.
Q

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And that was throughout your experience?
Yeah, it's usually dress-down day.

A

Same as
You know,

right now, you know, dress-down day.
you work a hal f a day and you go home.

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Alfred Sanford 11/9/2005

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

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Q

Was there any particular place that people went
on Friday afternoons?

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A

Yes, we used to go up to what we call the

Islander.

The Islander or the Clarion that

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Q

used to be on Bagley Road, we would go there

and have cocktails or something just to unwind
after work.

And that was it.

What about in the mornings? Tell me about your
observations in terms of when people would come
into work in the morning?

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A

Well, normally, everyone was usually in the
office at 9: 00, unless they had appointments or

something like that.

Sometimes -- a lot of

times I wouldn't be there in the mornings

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because I'm at doctor's appointments or
something like that, but on the occasions or times I was there, everybody usually is at
there working.
You want to go in there at 9: 00

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and you want to leave 5:00.
Q

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And was that

did you hear anybody say that,

is that sort of the expressed concept?
A

Oh, yeah, a lot of our loan officers stay quite

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a distance from the office.

You didn't want to

get caugh t in the rush hour traffic on the

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freeway, so you basically wanted to get out of

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Camille Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.
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at times that Heartland couldn't do the loan.
Bu t I'm golng to show thi s to you and as k you

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if this refreshes your recollection.

I'm also

going to provide a copy to your counsel.
MS. FISHER:

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I'm going to

make the same obj ection and request for all

future depositions, that the underlying

documents that make up this chart are produced
for all future deposi tions and all plaintiffs.

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A

And you're not required to believe that this
informa tion is correct.

Yes, I remember a lot of these customers are

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m1ne.
Q

Does that look right to you, you can see the
back-up documents underneath?

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A

Oh, yeah, I remember the names.

My customers

are basically repea t customers, so I remember
the name.
Q

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Does any of that look erroneous to you as you
look at it there?

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A
Q

No.

Looking at the dates, no.

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Okay.

Let's go ahead and mark that as

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De fendan t 's Exhibi t 3.

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(Defendant's Exhibit No.3 was marked.)

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like I said though -MR. CARR:
all you're enti tled to.

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And that 1S

MS. FISHER:

Please stop
You started

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interrupting me.
MR. CARR:

it, go ahead.

MS. FISHER:
MR . CARR:

Are you done?

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Yeah.
Okay.
You

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MS. FISHER:

don't scare me.

I already told you that.

Anyway, my objection is that for all future deponents, we're going to instruct them not to
answer your questions relating to this type of exhibit unless these documents are produced to

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us.

MR. CARR: Then we'll be
before the magistrate. Your obj ection is noted

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and we'll be before the magistrate on that.
Q

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Go ahead, Al.

That does refresh your

recollection?
A
Q

Oh, yes.
We've marked tha t as Defense Exhibi t 3.

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A
Q

I know these names.

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Okay.

Having had your recollection refreshed,

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tha t looks accura te to you?
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Q

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Yes.
So the document speaks for itself at this

point, but does that sound right, the numbers I

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came up wi th?
A
Q

I'm not holding you to exact

numbers, but 52 out of 123 brokered?

Yes.

I'm looking at the years of them, yes.

You started to talk about this a little bit.

Tell me what would cause you to broker a loan.
A

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Well, for one thing, the customers.

We get a

customer -- me, myself, you see, I couldn't see
gi ving a customer a nine percent rate when they

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qualify for a slx percent rate.

Again, put a

little old lady 1n a position where she will
lose her home.

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You know, that's not the way we
We jus t weren't trained that

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were trained.
way.
it to them.
Q

If a customer qualifies for it, you give

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Um- hum. And so, then, wha t would -- so wha t

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would cause -- I don't want to put words 1D
your mouth, but would cause you then to go

outside the Heartland family of offerings to go
to another lender?
A
Q

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What would cause me

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Yeah, what considerations came into play when

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Camille Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.
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vehicles.
Q

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So wha t, if any, advice do you give to the

customer 1n process?
A

I would tell the customer -- once I looked at

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all the numbers, I would basically give them
what we call a debt consolida tion worksheet.

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8 9

Show them if you payoff all this, this is your
savings a month; or if you don't, this is what
your savings is, and you still have those

10 11 12
Q

bi II s .

You try to maximize the biggest savings

you can to the customer.

And so, do you talk about advantages and

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A
Q

disadvantages?
Yes.
And do you help explain, then -- what, if any,

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explanation do you provide the customer as to

why a certain advantage exists or why a certain

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disadvantage exists?
A

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Well, it's basically 1S the customer -- if they
-- it's basically cash flow, what a customer is
looking at doing.

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If the customer -- I'LL ask

the customer how long they plan on being 1n
their home.

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That question can basically let me

know exactly what type of program to give to
the customer.

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I f they're only going to be in

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the home five years, why take a 30-year

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Q

mortgage?
Did you ever discuss mortgage sav1ng plans with

customers?
A
Q

5
6 7
8

Oh, yes.

Always.

And why is that?

A

Well, mortgage savings program is a biweekly
plan tha t if they pay -- if they make their

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payments biweekly, it takes seven years off on 30-year mortgage, it takes seven years off
their rate, especially if they have a low
credi t score and it's a nonconforming customer,

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it's a good program to use.

It gives them a

lower effecti ve interest rate.

A rate can be

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nine or ten percent, but wi th the mortgage

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sav1ngs program, their rate now becomes six
percent range.
You see, pl us it says seven

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years off your mortgage, plus the savings is
really tremendous.
Q

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Did you ever have occasion to visi t customers

at their homes or visit them in person?
A
Q

On occasions, yes.
How would tha t come about?

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24

A

We would basically go -- we call them IPVs,

25

in-person visits, where we would go directly to

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Camile Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.
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amount of paperwork that's involved.

And they

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have to basically get it checked off.

Normally, the manager checks off the paperwork
before any package goes to a customer.

You've

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8

got state specific documents and other
documents that have to be in there.

Q When, if ever, did these loan officers ask you
where they should broker a loan?

9

A They'll ask me if it's -- like, different
products, like 125 percent, and I would tell

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them the best brokers to use, that we basically
-- that I've used in the past.

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Q Can you describe for me how you think that you
add value or help the customers that call you
or talk to you?

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A Well, I give the customer -- I treat the
customer like they were -- like I would want to

be treated.

I make sure that I get them the

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best product out there, save them the most amount of money, and that they'll come back to

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me, or they'll give me a referral, they'll tell
a friend or family member.

A lot of my
I have customers

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business is due to referrals.

right now, that every two years they come back

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to me to refinance. And in this business,

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that's crucial.

2

Q They come back to you personal, you, Al
Sanford?

3
4

A Oh, yes.
Q And what percentage of your business would you

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8

say that is?
A

Oh, that's a lot.

Tha t l S a lot.

I would say

maybe 20, 30 percent.

9

Q And wha t, if anything, do you think that has to
do with how you treated them the first time

10
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14

around?
A If you treat the customer good, you glve them a
good product, they'll come back.

Q Can you gi ve any examples that come to your
head right now, specific people that are return

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A

customers?

Oh, sure. for he

I've got -- one customer, he works
works for the Times.
I did his loan;

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he was over in India somewhere, Pakistan, and

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he had to refinance.

So I refinanced him from
He called me a year

all the way over there.

and a half later, Al, I need some money to do
an addi tion to my house.

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24

I did it for him

aga1n.
I have another young lady in Virginia,

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she owns three homes.

I refinance her every

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two years.

I just got through refinancing her,

all three homes, every two years.

Q What was your understanding of the draw program
for -- at Heartland -- or what is your understanding of the draw program?

5

6
7 8 9

A Well, you -- if you don't close any loans, you
get what they call a draw.
you get that draw.

Okay? Tha t draw

Tha t 's to keep you wi th
After you get the

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some money in your pocket so you can get
backwards and forth to work.

draw -- when you close a loan, you pay back the

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draw.

Q And have you had pay periods where you didn't
A

15

16
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Oh, yes.

Oh, yes.

Oh, yes.

Q Turning back now to the issue of hours, did you
ever hear -- do you have contact wi th, say, the
regional managers and Don Flynn, the owners of
the company?

19

20
21 22

A Yes.
Q What, if anything, have you ever heard them say
about the hours that you are supposed to work?

23
24

A It's always 40 hours, that's it.
Q And you've never heard anything di fferent than
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identification as Defendant's Exhibi t 4.

Tell

2 3
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me, do you recogni ze tha t?
A
Q

Yes.
1st hat a - - tel 1 me, w hat i s t hat doc ume n t ?

5 6 7
8

A

Okay.

I was receiving letters -- I had signed

up for the lawsui t, and then I got out of the
lawsui t.

So, you know, when I got a letter, I

sent this letting them know that I no longer

9

wanted to be part of the lawsui t.
Q

10
11
12

How was this sent, was it sent regular mail or
faxed or how did you deliver it?

A
Q

I believe this was faxed.
So as we si t here today, are you suing

13
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Heartland Home Finance?
A
Q

15

No.
What, if any, hours did you work over 40 1n a

16
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week?
A
Q

Over 40? None.
Well, Ms. Fisher 1S sitting right here.
Do you

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20 21 22 23
24
A
Q

consider her to be your attorney?

No, I don't have an attorney, really.
You don't have an attorney?
I don't need an attorney, no.

A
Q

Well, do you consider Ms. Fisher to have ever

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been your attorney?
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Q

A couple times.

52

Now, understand 1'm only

2 3
4

talking about since June of 2004, since the

time after which you no longer considered them
to be your attorneys.
A

5
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8 9

I haven't had that much conversation wi th them
since then.

Q

All right.

When was --

A

Outside of letters, but other than that, that's

it.
Q

10
11
12

You continue to get letters from them?

A
Q

Yes.
How many letters did you get from them?

13
14

A

Oh, I've got several.
lawsui ts.

Some for different

15

Q

And did you respond to these letters at all?
No, I never sent -- no.

16
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A
Q

And what, if anything, did they say to you
after the time that you no longer considered
them to be your attorneys?
MS. FISHER:

19

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21
22

I'm going to

object to the extent that if we find out this

was any sort of setup by the company, there are
going to be some serious consequences here, Mr.

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Sanford.

You should be aware of that as well.

25

This is inconsistent with the conversations

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nobody would be com1ng 1n here gl v1ng

56

2 3
4

depositions like that.
Q

Like what, what are you specifically referring

to?
A
Q

5 6
7
8

Overtime and all the nonsense.

Well, why do you call it nonsense?

A

Because, you know, the environment of the

company 1S, you know, just -- at least with my

9

tenure wi th Judy and us, we didn i t have those
kinds of problems, people was always talking
abou t

10
11

you know, they had to work long hours
If anything, we were pretty much

12

or anything.
laid back.
Q

13
14

What, if any, contacts did you have with other

15

teams?
A

16
17 18

Oh, I saw them constantly.

We would go out to

-- on Fridays to different clubs, and we had different events that the office did -- you
know, would sponsor, boat trips and stuff like

19

20 21 22 23
24
A
Q

that. And I didn't see any -- why they would
be so angry.
Anything el se tha t serves as a basi s for your

observations about the other teams?

A couple -- a couple of them that I worked
wi th -- I worked wi th some of them, you know,

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Alfred Sanford 11/9/2005

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

57
1

we socialized with, and, you know, to me, they

2 3
4
Q

worked -- some of them, they didn l t even work
20 hour s .
Do you have any idea, based on your

5
6

observations, what would be motivating them to
claim overtime that they didn't actually work?
A
Q

7
8 9

Money.
What, if anything, else did Ms. Fisher tell
you, or anyone else from Nicholas, Kaster,

10 11
12

after you no longer considered yourself to be
their client

to be their client that you

haven't already testified to?
A

13
14

Nothing.
MR. CARR:

I have no

15

further questions.

16 BY MS. FI SHER:
17 18
Q

Mr. Sanford, I have some follow-up questions
for you.

19

You do realize today that you are under
oath to tell the truth, right?
A
Q

20
21 22

Yes, I do.

Do you recall having a conversation with me

23
24

yesterday where, on the phone, where I asked
you if you wanted to be part of this lawsuit

25

because I reviewed your personnel file and

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Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
70
1

A
Q

The manager always said 40 hours.

2 3
4

Are you aware of any loan officers working more
than 40 hours on your team?
I know the other

teams were on different floors.
A
Q

5
6 7
8

No, not to my knowledge.

Were you keeping their time?
No, you as ked me did I know.

A

Not to my

knowledge, I didn't know.
Q

9

But you weren i t keeping their time?

10
11

A
Q

No.
You weren't the timekeeper assigned 1n the

12 13
14
A
Q

office?
Oh, no.
Oh, no.
So it's pos sible, then, they could have been

15

working overtime hours that you' ré not aware

16
17
A

of?
It's possible.

Not too likely, though, because

18

I'm usually the first one there and I'm usually
the last one to leave.
Q

19

20
21 22

You don't know when they're out on

appointments?
A
Q

That's true.
Isn't it true that all of your leads were

23
24

supposed to be sent through Heartland's bank
first, and then if they were rejected, you

25

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