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

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

Document 339-25

Filed 01/31/2006

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IN THE UNITED .STATES DISTRICT COURT
FOR THE DI STRICT OF COLORADO

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CAMILLE MELONAKIS-KURZ,

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et al.,

Plaintiffs,

vs. CASE NO. 03-MK-2485
HEARTLAND HOME FINANCE, INC.,

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Defendant.

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* * *
Deposi tion of EDWIN E. KIRKLAND,

Plaintiff herein, called by the Defendant for cross-examination pursuant to the Rules of Civil Procedure, taken before me, Kathy S. Wysong, a
Notary Public in and for the

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State of Ohio, at the

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offices of Mike Mobley Reporting, Inc., 334 South
Main Street, Dayton, Ohio, on Monday, January 9,
2006, at 8: 00 a.m.

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

Document 339-25

Filed 01/31/2006

Page 2 of 2

Edwin E. Kirkland 1/9/2006 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
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Q.

Just focusing on the period of

2 time when you were a loan officer and senior
3 loan officer, can you briefly describe to me

4 what your duties were?
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A.
Q.

I sold loans.

And how did you do that?

A.

Well, we -- like I was telling you

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Q.

Uh-huh.
-- we had a couple different ways.

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A.

Heartland was very good at making

sure we had leads.

That's one of the things

13 that I used to hate about employees saying we
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don't have any calls to make.

15 Don did a great job of making
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us leads every morning.

That's not true.

16 sure -- they had a sales division, a marketing

17 division, or something like that that provided
Now, it may not be

19 8:00 a.m. but it would be by 10:00 or 11:00,

20 whatever because we didn't have to call them
21 until that evening and those leads were handed

23 Obviously if you were good at
24 selling loans, you got some of the better
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leads.

Somebody tha t was brand-new to the

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