Exclusive Bombshell of Foreclosure Fraud – Full Deposition of TAMMIE LOU KAPUSTA Law Office of David J Stern Posted by 4closureFraud on October 7, 2010 · 19 Comments

HEY JUDGE COX, THIS IS WHAT THE MOTION TO QUASH IS PROTECTING!

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MY GOD!

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WHERE ARE THE FEDERAL AGENTS!!!

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“I personally did not do it because I refused to do it.”

“I wasn’t going to falsify a military document.”

“I was told that that’s fine, somebody else on your team will do it.”

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This just in and it is unbelievable!

We are neck deep in issues today so I do not have time to go through and highlight everything, and there is a lot, but here are some snips…

TAKE THE TIME TO READ THIS IN ITS ENTIRETY

THIS SHOULD BE THE BOMBSHELL THAT STOPS IT ALL IN FLORIDA

MORE TO FOLLOW ON THIS

1 STATE OF FLORIDA

OFFICE OF THE ATTORNEY GENERAL

2 DEPARTMENT OF LEGAL AFFAIRS

3 AG # L10-3-1145

4

5 IN RE:

6 INVESTIGATION OF LAW OFFICES

OF DAVID J. STERN, P.A.

7

8 ____________________________/

9

10

11

12 DEPOSITION OF TAMMIE LOU KAPUSTA

13

14

15

16 12:11 p.m. – 1:58 p.m.

September 22, 2010

17 Office of the Attorney General

110 Southeast 6th Street, 10th Floor

18 Fort Lauderdale, Florida 33301

1 P R O C E E D I N G S

2 – – –

3 Deposition taken before Kalandra Smith, Court

4 Reporter and Notary Public in and for the State of

5 Florida at Large, in the above cause.

6 – – –

7 THEREUPON:

8 TAMMIE LOU KAPUSTA

9 having been first duly sworn or affirmed, was examined

10 and testified as follows:

1 Q Let’s go to the assignments of mortgage. They

2 were prepared in-house?

3 A Yeah.

4 Q You’re smiling. You want to tell me about

5 them?

6 A Assignments were done sometimes after the

7 final judgement was entered.

8 Q Do you know why that is?

9 A Because that’s what we were directed to do

19 Q Can you tell me the execution of the

20 assignments, how it worked?

21 A Assignments were prepared again from the

22 casesum. All of our stuff comes from the casesum. They

23 would be stamped and signed by a notary or not. Per

24 floor we had a designated spot to place them and Cheryl

25 would come once a day and sign them.

22

1 Q Sign them as what?

2 A As —

3 Q For the bank?

4 A Correct.

5 Q Or for MERS or whoever it was for?

6 A Correct.

7 Q Would these notaries be there watching her as

8 she signed?

9 A No.

10 Q She would just sit there and sign stacks of

11 them?

12 A Correct. As far as notaries go in the firm I

13 don’t think any notary actually used their own notary

14 stamp. The team used them.

15 Q There were just stamps around?

16 A Yes.

17 Q And you actually saw that?

18 A I was part of that.

19 Q You did it? Are you a notary?

20 A No, I’m not.

21 Q Did you sign as a witness?

22 A I did not. I signed as a witness on one

23 document and after that I decided that I didn’t want to

24 put my name as a witness anymore.

25 Q Tell me about the stamps. You stamped them?

23

1 A Yeah, I had stamps. Each team had a notary on

2 them or notaries that I was aware of. Whether they were

3 or weren’t wasn’t —

4 Q You had stamps?

5 A Correct. We would stamp them and they would

6 get signed.

7 Q Stamp them in blanks?

8 A Yes.

9 Q Who would sign them?

10 A Other people on the team that could sign the

11 signature of the person or just a check on there or

12 whatever.

13 Q Was that common practice?

14 A Yes.

15 Q Was that standard practice?

16 A Pretty much.

17 Q What about the witnesses?

18 A Those would be signed by juniors who were —

19 Q Standing there?

20 A Here, sign this. It has to go to Cheryl, sign

21 it. Then it would go and sit at the desk where Cheryl

22 would sign everything.

23 Q Out of view of the notary and out of view of

24 the witnesses?

25 A Correct.

24

1 Q Do you know who implemented this procedure?

2 A Cheryl.

3 Q Cheryl did?

4 A Um-hum.

5 Q Did anybody else sign with the firm for the

6 banks?

7 A Yes.

8 Q Who was that?

9 A There were people that were responsible for

10 signing Cheryl’s name. Cheryl, Tammie Sweat, and Beth

11 Cerni. Those were the only three people that could sign

12 Cheryl’s name. If you ever look at assignments you’ll

13 see that they are not all the same.

14 MS. EDWARDS: What are the names again?

15 Cheryl, Tammie?

16 THE WITNESS: Tammie Sweat and Beth Cerni.

17 MS. EDWARDS: Could you spell that.

18 MS. CLARKSON: C-E-R-N-I.

19 BY MS. CLARKSON:

20 Q Did they practice Cheryl’s signature?

21 A I would assume so.

22 Q Did you ever see them?

23 A Not practicing but I’ve seen them sign it.

24 Q Did you see somebody sign Cheryl’s name?

25 A Yes.

25

1 Q That wasn’t Cheryl?

2 A Yes. All the time.

3 Q Did Cheryl know about this?

4 A Yes.

5 Q Was it at her direction?

6 A Yes.

16 Q Did anyone quit as far as you know due to the

17 practices?

18 A I’m sure but they wouldn’t come right out and

19 say I quit because of the practices. I know that people

20 had left because they were uncomfortable with the things

21 that they were being asked to do, as most of us were.

22 When it got really sticky there were a lot of us that

23 weren’t here.

24 Q What does really sticky mean?

25 A They wanted us to start changing the documents

33

1 and stuff and doing stuff that we weren’t supposed to be

2 doing as far as service.

3 Q What documents did they want you to change?

4 A Manpower documents. A lot of judges started

5 requiring, because of the Jane and John Doe issues,

6 required that you have a military search for all the

7 defendants. If you named a Jane and John Doe as an NKA

8 you had to pull a military search on them. Unless you

9 have somebody’s social security number technically you

10 can’t pull a military search supposedly.

11 The program that we used for the program that

12 we used, you could put in the main defendant’s social

13 security and John or Jane Doe’s name and it would give

14 us a military search saying that they were in the

15 military.

16 Q You would get their social security number

17 because the bank documents contained it?

18 A Correct. The lenders, the referrals had the

19 socials.

20 Q Did you put the social in on everybody to find

21 out their address for service?

22 A Not everybody. I personally did not do it

23 because I refused to do it. I wasn’t going to falsify a

24 military document. I was told that that’s fine,

25 somebody else on your team will do it.

1 Q What do you mean falsify a military document?

2 A Well, I’m using the main defendant’s social

3 security number on somebody else’s name, not his name.

4 John Doe and the main defendant was James, I was taking

5 James’ social security number and putting John Doe’s

6 name in there. I wasn’t but that’s what the practice

7 was. The judges started saying we’re not going to

8 consider service completed until —

9 Q There’s a miliary search?

10 A Correct.

11 Q So why wouldn’t they use the right social

12 security number for the right person?

13 A Because you don’t have a social for an NKA or

14 unknown tenant. They wouldn’t enter a final judgement

15 unless the military doc was there.

16 Q So you just used anybody’s?

17 A Correct.

9 A So what we had to do from that point, again

10 the affidavits were still split in two pages, at that

11 point we were supposed to be sending them back to the

12 banks to be signed now. The problem being that a lot of

13 times we wouldn’t get them back or executed in time for

14 the hearings. So we had what they called signature

15 pages that Tammie Sweat or someone else would have in

16 their possession. If we couldn’t get it back from the

17 bank executed in time we would just take a signature

18 page and put it on the affidavit.

19 Q What was on the signature page?

20 A The signature and notary from the bank.

21 Q Were these documents photocopied or were they

22 original documents?

23 A Some were photocopied.

24 Q How would you get that many from a bank

25 original? The bank supplied them to you.

42

1 A Well, what would happen would be like if I had

2 file A and that one didn’t go to hearing because there

3 was something wrong with it and file B was going to

4 hearing but it was the same bank, I would take the

5 signature page from A and give it to B.

6 Q Oh give it to another file?

7 A And just re-execute this file.

8 Q Okay. That was common practice?

9 A Yes, after Cheryl couldn’t sign.

10 Q Did Cheryl know?

11 A Yes.

12 Q Cheryl knew about all the practices because

13 she is the one who ran the office?

14 A She was the one who implemented them.

15 Q Were there any other activities or practices

16 over at David Stern’s firm that made you feel

17 uncomfortable or that you were unwilling to do?

18 A I don’t know how to answer that question.

19 It’s a loaded one.

20 Q Take your time.

21 A Yeah. Some of the things that were done there

22 just were not on the up and up.

23 Q Explain to me in as much detail as you can

24 what those things were.

25 A I don’t even know where to start with it.

Now that’s some BULLSHIT!

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MUCH MORE IN THE DEPO BELOW…

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4closureFraud.org

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Full Deposition of Tammie Lou Kapusta Law Office of David J Stern

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