Case 1:03-cv-02485-MSK-PAC
Document 339-19
Filed 01/31/2006
Page 1 of 4
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IN THE UNITED STATES DISTRICT COURT FOR THE DI STRICT OF COLORADO
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CAMILLE MELONAKI S-KURZ, )
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employees, )
of other similarly
individually and on behalf) situated)
Plaintiffs, )
) )
)
vs.
INC. ,
No. 03 - MK - 2 4 8 5
HEARTLAND HOME FINANCE,
)
) )
Defendant. )
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CC~
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VIDEOTAPED DEPOSITION OF TERENCE GUNN,
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12 produced, sworn, and examined on Tuesday, the 6th
13 and 5: 33 in the afternoon of that day at the
day of December, 2005, between the hours of 3: 12
17 of100 18 Suite
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16 ELLEN L. STOCK, RMR
offices of Jay E. Suddreth & Associates, 10104 West 14 105th Street, in the City of Overland Park, County of Johnson, State of Kansas, before: 15
Certified Shorthand Reporter
JAY E. SUDDRETH & ASSOCIATES, INC.
10104 West 105th Street
19 Overland Park, KS 66212-5746
a Certified Shorthand Reporter in and for the State
22 Taken on behalf of Plaintiffs pursuant to Notice to
Take Deposi tion.
23
'f24 ,$'25
21 of Kansas.
Case 1:03-cv-02485-MSK-PAC
Document 339-19
Filed 01/31/2006
Page 2 of 4
Terence Gunn 12/6/2005
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
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A.
Q.
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Ab 0 u t 5 5 .
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Okay. What was your typical weekly
s chedul e?
A.
9 : 30 some
15:15:14 15:15:15 15:15:16
to 7:30 Monday through Friday. 15:15:27
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And Saturday we would show up, say, nine
0' clock to one 0' clock.
Q.
Nine o'clock to one o'clock on Saturdays?
A.
Q.
Um-hum.
Urn-hum.
I need make sure
I forgot to
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Okay.
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remind you 0 f thi s when we started -- tha t
you answer verbally with yes or no rather
than using urn-hum.
A.
Q.
Yes.
Okay.
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A.
Q.
Thank you.
Did you typically take a lunch?
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15:15:33 15:15:40 15:15:43 15:15:44 15:15:46 15:15:49 15:15:52 15:15:52 15:15:53 15:15:53 15:15:53 15:15:56
15:16:05 15:16:09 15:16:10
A.
No. Most of the time I would have lunch at 15:16:00
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my desk.
Q.
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Okay. And when you ate lunch at your desk,
were you still working?
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';, ;o
A.
Q.
Yes. 15:16:10
And ls your 55 hour per week estimate based 15:16:14
on the schedule that you just gave me?
Approximate -- yes.
A.
Q.
15:16:17 15:16:18
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Okay. Did you keep any sort of time sheets
Paradigm Reporting & Captioning Inc.
612-339-0545
Case 1:03-cv-02485-MSK-PAC
Document 339-19
Terence Gunn 12/6/2005
Filed 01/31/2006
Page 3 of 4
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
59
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credit, and go through the bills and -- how 16:35:51
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did you know what it was that the customer i s 16: 35: 53
goals were? 16:35:54
A.
Q.
How did we know?
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Um-hum.
From pulling their credi t report. And you
add up how much they're spending.
A.
Q.
Well, did customers have different goals or
desires?
A.
Q.
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Yes.
Okay. What sort of -- first off, how would
you know what their goals or desires were?
16:35:55 16:35:56 16:35:58 16:36:00 16:36:04 16:36:04 16:36:05 16:36:08 16:36:10
16:36:14 16:36:16 16:36:21 16:36:26 16:36:29 16:36:31 16:36:32 16:36:34 16:36:35 16:36:39 16:36:40
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A.
Well, you interview with the customer. When 16:36:13
you talk wi th the customer on the phone.
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When you call the lead that Heartland
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Q.
provided. Whether it was Internet lead or
telemarketing lead.
And then would there be different programs
depending upon what their needs were? A.
Q.
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Yes.
Can you give me some examples of wha t those
would be?
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A.
Needs vary.
Some of them may want to
consolidate.
Some want -- probably want to
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get on an adjustable.
Different
Paradigm Reporting & Captioning Inc. 612-339-0545
Case 1:03-cv-02485-MSK-PAC
Document 339-19
Terence Gunn 12/6/2005
Filed 01/31/2006
Page 4 of 4
Camile Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
60
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scenarios.
Q.
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Okay.
So if someone wanted to consolidate,
would there be a di fferent type of product
that would tend to be better for them?
A.
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No.
Just what we had to offer.
You know.
Everything was score driven.
If they had a
great FICO score, they would probably get a
16:36:44 16:36:48 16:36:50 16:36:51 16:36:54 16:36:57 16:37:00
preferred rate.
If it wasn't a great score, 16:37:03
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then they would probably look at a
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non-conformant loan.
Q.
Okay. What's a FICO score? What's that?
I'm sure -- you're not familiar with the
A.
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FICO score?
Q.
I'm familiar with it, but we need to
establish for our record what that is.
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A.
Q.
A FICO is your credi t score.
Now, what about in terms of establishing,
like, origination fees.
How did you go
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about doing that?
A.
Origination fees was something that --
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tha t 's the onl y way we got paid.
So we had
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to try to establish whatever fee we felt,
you know, from the customer -- that you had
a good feel from the customer that they
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would pay.
It's the only fee we got
Paradigm Reporting & Captioning Inc.
612-339-0545