deposition of erica johnson seck

8/2/2019 Deposition of Erica Johnson Seck

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1. Ms. Seck discloses "TRUE" note-owner is... DEUTSCH BANK NATIONAL TRUS

2. " discloses Securitization of Loan

3. " " discloses Indymac/ Onewest Banks "DO NOT OWN THE LOAN"


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1. Ms. Seck discloses if "Indymac the plaintiff" wins this lawsuit "DEUTSCH BANK"

is the party who "Collects" the proceeds or the "House" at the end of the day.

2. " " discloses she has LPOA as Attorney-in-Fact & VP of Indymac.


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1. Ms. Seck disclose Counsel for Plaintiff was informed who the "TRUE" note owner

"DEUTSCH BANK" is from the beginning

2. " " discloses after Judgment, Plaintiffs counsel knows to transfer of bid to

"DEUTSCH BANK"


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1. Ms. Seck discloses "Confidentiality Agreements" in Settlements against borrowers

2. " " does not answer if Fraud Allegations of the Indymac/Onewest were committed

in order to settle


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1. Ms. Seck discloses Plaintiffs Counsel was informed who owns the Loan/Note bya "Transmittal Letter" submitted by plaintiff from DAY 1

2. " " discloses Plaintiffs Counsel knew the loan was securitized from DAY 1

3. " " discloses she IS NOT AN OFFICER OF MERS but Indymac Bank


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1. Ms. Seck discloses she is NOT authorized to sign as "VP of MERS"

2. " " discloses she is not a paid employee of MERS

3. " " discloses she does not attend ANY board meetings of MERS

4. " " discloses she does NOT report to any President of MERS

5. " " discloses she has NO NONE involvment with governance of MERS


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1. MS. Seck discloses she does not know anything about MERS but she DOES know

she is executing as Vice President and Assisant Secretery for MERS all over thecounrty.

2. " " discloses plaintiff counsel prepared drafts Assignment of Mortgage


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1. Ms. Seck discloses regardles who the Note Owner/ Holder "MERS CANNOT"

foreclose and MUST be ASSIGNED to Indymac the servicer NOT the Note Owner

Deautsch Bank to foreclose


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1. MS. Seck discloses MERS "never" assigned title because it never had the Note.

2. " " discloses "ROGER STOTTS" is CAO & A VP for Indymac her "Peer"


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1. Ms. Seck discloses Plaintiff Indymac is NOT identified in MERS records system

as an "Investor" but as a "Servicer"


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1. MS. Seck is questioned on a previous NY case where the Judge asked for an affid

from Ms. Seck requesting she discloses her employee histiry for the past 3 years.

2. "JUDGE wanted to know if she was self engaged in wearing "2 Corporate Hats"


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1. OTHER cases involving Ms. Seck


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1. Ms. Seck discloses "how" the process of a foreclosure is commenced via a

"Transmittal Package"(a) A Document is issued to an approved attorney

(b) " " tells the attorney in whos name to sue in

(c) " " tells attorney in whos nam to "VEST TITLE" into DEUTSCH BANK NATION


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1. Ms. Seck discloses NO DOCUMENT tells Plaintiffs counsel there is a "LOST NOT

2. " " discloses no AGREEMENT/Contract exist between Indymac/Onewest or

Plaintiffs "COUNSEL"


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deposition of erica johnson seck

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