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

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

Document 339-2

Filed 01/31/2006

Page 1 of 4

EXHIBIT A

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

Document 339-2

Filed 01/31/2006

Page 2 of 4

1

Volume I, Pages 1-126
Exhibi ts: 1-7

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

-- - - ---- - - --- - -- - -- - - - - ---Camille Melonakis-Kurz,

Individually and on behalf of
other similarly si tuated employees

Plaintiff
vs.
Heartland Home Finance, Inc.

Docket No. 03-MK-2485

Defendant

-- - --- - -- ----- - - - ---- - ----- -VIDEOTAPED DEPOSITION OF ROBERT P. ACCETTA
Tuesday, January 17, 2006, 9:41 a.m.

50 Congress Street, Suite 415
Boston, Massachusetts

CêOPY
-------Reporter: Joan M. Cassidy, RPR, CRR-------

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

Document 339-2

Filed 01/31/2006

Page 3 of 4

Robert P. Accetta 1/17/2006

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

1 New Hampshire, we found that the notary really did

34

2 not have a lot of information, I guess is probably
3 the best way to put it, about the mortgage process.
4 They were just there to real ly make sure the person

5 was the person who they said they were and to stamp
6 the forms as opposed to explaining any questions

7 that might have come up at the closing.
8

Q.

Okay.

So in those situations you would

9 answer the quest ions that the client had?

10 A. Yes.
11 Q. While you were a senior loan officer at

14 A. A little.
16
A.

12 Heartland, were your duties different from when you 13 were a loan officer at Heartland?

15 Q. And how's that?
The expectation was that, you know, you

1 7 were to be a leader, that when the manager wasn't

18 there, you were the next person in charge.
19
Q.

As a senior loan officer, did you ever

20 train any loan officers while you were at Heartland?
21 22
A.
Q.

I helped train some.

Who did you help train?

23

A.

Specific names or -- what are you looking

24 for?
25
Q.

I'm sorry, that was an unfair question.

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

Document 339-2

Filed 01/31/2006

Page 4 of 4

Robert P. Accetta 1/17/2006

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

1

A.
Q.

Okay.
Who were you helping to train them?
You need to clarify that.

35

2

3
4

A.
Q.

Okay.

You said that you would help train

5 the loan officers?
6

A.
Q.

Yes.
Who else was training them?
The manager.

7
8

A.
Q.

9

So you would assist the manager in training

10 the loan officers?
11 12

A.
Q.

Yes.
Did the loan officers ever ask you

13 questions wi thout going to the manager first?
14

A.
Q.

Yes.
And what kinds of questions would they have

15

16 in those instances?
17
A.

In some areas it might be just "what do I

18 do next" in terms of the process, or "how do I do
i 9 the next thing" to -- again, maybe just helping them

20 look at scenarios as well.
21

Q. As a senior loan officer, did you ever

22 recommend scenarios to your manager?
23
24
A.
Q.

I'm not sure if you mean for myself or --

Did the managers -- did the manager, while

25 you were at Heartland, also close loans?
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