485 Lexington Avenue

~
New York, NY l0017
Tel: 646·722-8500
Fax: 646-722-8501

Grant & Eisenhofcr PA 1747 Pennsylvania Avenue, N.W., Suite 87 5

Washington, DC 20006
123 Justison Street Wilmington, DE 19801 Tel: 302-622-7000 Fax: 302·622-7100 Tel: 202-386-9500
Fax: 202-386-9505

30 N. LaSalle Street, Suite 1200

WRITER'S DIRECT DIAL NUMBER Chicago, IL 60602
Tel: 312-214-0000
Fax: 312-214-000I
Direct Dial: 302-622-7053
E-mail: jvictor@gclaw.com

October 31, 2013

VIA OVERNIGHT MAIL

Ms. Fran Trapp

United States Attorney
District of South Carolina
1441 Main Street, Suite 500
Colombia, S.C. 29201

Re: United States ofAmerica et al. ex rel. Laurence Schneider v. J.P. Morgan
Chase et al, 3:13-1223-CMC(D.S.C.)[under sealJ

Dear Fran:

Please find enclosed a witness list prepared with the assistance of the Relator, Laurence
Schneider. The witness list is provided in both a hard copy and electronic form for your
convenience.

If you have any questions, please do not hesitate to call me at 302-622-7053.

Sif~e4Jl,
till -·
Jlstin K. Victor
Counsel for Relator

JKV/nn
Enclosure

cc: William C. Edgar, Esq. (with enclosure)

RichardA. Harpootlian, Esq. (with enclosure)
Laurence Schneider (with enclosure)
 Witness List

A. Primary List

Name Position Address and Contact Information

Current Emplovees

Launi Solomon Recovery Operation 1820 E. Sky Harbor Circle S, Phoenix, AZ

Supervisor: February 1997 to 85034
Tab 1 Present. 602-627-8548-0
launi.l.solomon@chase.com

Patrick "Mike" VP Loss Mitigation and 1820 E. Sky Harbor Circle S, Phoenix, AZ
Boyle National Recovery: 2009 to 85034
Present. 602-627-2489-0
Tab2 patrick.m.boyle@chase.com

Omar Kassem Portfolio Manager of Federally AVP Portfolio Management

Regulated Mortgage Loans:
Tab3 September 2010 to Present
JPMorgan Chase Bank
1820 E. Sky Harbor Circle S, Phoenix, AZ
85034
602-627-8661-0
omar.kassem@chase.com

Home
24114 N. 24th Place, Phoenix, AZ 85024
480-650-9995-C

Jeffrey Loss Mitigation Supervisor 1820 E. Sky Harbor Circle S, Phoenix, AZ

McGrane** 85034
602- 627-7356-0
Tab4 jeffrey.s.mcgrane@chase.com

Home
2720 E Azalea, Chandler, AZ 85286
480-234-1189-C
jeffmcgrane@msn.com
Jason Oquendo Vendor Relationship Manager: 1820 E. Sky Harbor Circle S, Phoenix, AZ
October 2008-January 2011. 85034
Tab5 602-627-8687-0
Manager of Audit & 480-559-2355-C
Compliance: January 2011 to jason.m.oquendo@cbase.com
Present.

Assistant Vice
President/Business Process
Manager: May 2013- Present

Mark Davis Vice President, Chase Irving, TX

Recovery - supervisor of 972-443-5751-0
Tab6 Patrick Boyle mark. w.davis@jpmchase.com

Former Employees

Jason Richmond Information Analyst: Feb 2008 Phoenix, Arizona

-May 2012.
Tab 7
Currently works at Wells
Fargo as an Analytics
Consultant as of May 2012.

Victor Fox Former VP Real Estate Raleigh-Durham, North Carolina

Recovery
Tab8
Currently SVP Lending
Services, Default Operations
PNC
 B. Secondary List

Name Position Address and Contact Information

Stephanie Head of Global Retail stephanie.b.mudick@chase.com

Mudick Strategy/DOJ Oversight

Tab 9

Joy Palazzo Assistant General Counsel/DOJ joy.e.palazzo@chase.com

Legal
Tab9

Steve Mackey SVP & Risk Executive stephen.c.mackey@chase.com

Mortgage Banking/DOJ Risk
Tab9

Kevin Smith Managing Director & Chief kevin.r.smith@chase.com

Control Officer/DOJ Controls
Tab9

Lynn Newby AVP Operations Manager/DOJ

Compliance
Tab9
 Launi Solomon

The Relator has worked closely with Launi Solomon for approximately eight years.
During this time they have exchanged hundreds of emails and had numerous phone
conversations.

Ms. Solomon works at Chase as a support supervisor for their Recovery Operations
Department. In this position, she was the gatekeeper for providing post-loan sale support. These
support activities included providing individual note sale approval letters, ordering and sending
the original loan servicing and collateral loan files, executing assignment of mortgages, and
endorsements on promissory notes.

Ms. Solomon will be able to confirm that Relator's loans were forgiven by Chase without
first checking to see if the mortgage loans were still owned or serviced by Chase. She will also
be able to confirm that Chase did not make any attempts to contact individuals to confirm they
were living in the property before sending loan forgiveness letters. She will be able to confirm
that all communications with these borrowers were coded as if they were assigned to collection
agencies. She will also be able to confirm that there are currently over 150,000 loans which
Chase owns or has contractual servicing obligations that are assigned to collection agencies for
all communication with borrowers.

On August 15, 2013, Mr. Solomon informed the Relator that she was no longer allowed
to provide any note sale support for the mortgages he purchased from Chase and that she had
been instructed to cut off all communications with the Relator.
 Patrick ''Mike" Boyle

The Relator first had contact with Mike Boyle in November 2009.

As V.P. of Loss Mitigation and Recovery Operations, Mr. Boyle Boyle played a
prominent role in the spearheading of the "2nd Lien Extinguishment Program." Mr. Boyle was
the direct supervisor of Omar Kassem who is V .P. Portfolio Manager of Mortgage Banking and
Jason Oquendo who is V.P. of Audit and Compliance as well as Project manager for the DOJ 2 nd
Lien Extinguishment Program.

Any decisions made by Omar Kassem and Jason Oquendo were directed and approved by
Mr. Boyle. Mr. Boyle's name appears on all 50,000 loan forgiveness letters sent to out to
borrowers, including those in which the Relator owned.
 Omar Kassem

The Relator emailed Mr. Kassem in September 2012 when mortgages he owned were
improperly forgiven by Chase. On December 15, 2012, Mr. Kassem emailed the Relator offering
to buy-back certain loans that were improperly forgiven.

Mr. Kassem has direct knowledge that Chase did not reach out to borrowers and ensure
borrowers still owned the mortgage or were even living in houses for the mortgages that were
forgiven. Mr. Kassem can confirm that large pools on invaluable loans were forgiven without
considering whether these mortgages qualified for "Consumer Credit" under the terms of the
National Mortgage Settlement Agreement.
 **Jeffrey McGrane**
Through years of purchasing mortgages from Chase, the Relater has developed a
friendship with Jeff McGrane. Mr. McGrane provided the Relater many of the documents, email
chains, and information used to support his claims when Mr. Kassem and other Chase employees
stopped communicating with him.

The Relater is concerned about protecting Mr. McGrane from repercussions at Chase.
 Jason Oquendo

The Relator interacted with Jason Oquendo in 2008, when Mr. Oquendo requested
information from the Relator before the Relator's purchase of nearly 3,500 "1 st Lien Mortgage
Loans" from Chase in 2008.

The Relator believes that Mr. Oquendo has intimate knowledge of Chase's internal
practices and procedures of "charging off' loans as if they are unsecured when Chase determines
that the loans have little to no value. These loans were moved to a portfolio titled "RCVI." The
Relator believes that loans within the RCVI portfolio - which were internal classified within
Chase as practically worthless and thus reported as such in quarterly financials - were selected to
be forgiven to meet Chase's obligations under the terms of the National Mortgage Settlement
Agreement. Mr. Oquendo would be able to confirm that Chase never reached out to confirm if
these properties were occupied before the mortgages were forgiven.
 Mark Davis

The Relator had an email exchange with Mark Davis in November 2009 concerning a
pool of 3,500, 1st Lien Mortgage Loans he purchased from Chase in February 2009.

Mr. Davis is the direct supervisor of Patrick "Mike" Boyle who signed all of the 2nd Lien
Extinguishment letters which were sent out to borrowers for "Credit" under the National
Mortgage Settlement Agreement.

Mr. Davis may have recently left his position with JPMorgan Chase.
 Jason Richmond

The Relater never spoke directly with Jason Richmond. He was copied on emails
between the Relater, Eddie Guerrero and Victor Fox in 2008.

Mr. Richmond is familiar with the policies and procedures regarding "charged-off' loans.
These are no longer active in Chase's servicing portfolio and thus moved to the "RCVl"
portfolio. Mr. Richmond was responsible for the transfer of data from the Recovery Department
to collection agencies and back. Mr. Richmond knew that many of the loans included in this
loan pool were improperly documented and filled with numerous inaccuracies concerning who
actually owned the rights to the loans and the lack of integrity regarding specific borrower loan
information. These are loans that were forgiven in Chase's 1st Mailer to meet its obligations
under the National Mortgage Settlement Agreement.
 Victor Fox

Victor Fox is also familiar with the policies and procedures regarding "charged-off'
loans. Mr. Fox also knew that many of the loans included in this loan pool were improperly
documented and filed with numerous inaccuracies concerning who actually owned the rights to
the loan. These are loans that were forgiven in Chase's 1st Mailer to meet its obligations under
the National Mortgage Settlement Agreement.

Victor Fox was direct supervisor over Eddie Guerrero,_Jason Oquendo and Jason
Richmond. His role was similar to the current position that Patrick Boyle now holds.
 Stephanie Mudick, Joy Palazzo, Steve Mackey, Kevin Smith, and Lynn Newby

The Relator has not had any direct contact with these employees. ·

However based on the documents provided by Jeff McGrange, it appears that these are
the key decision makers which make up the Internal Review Group ("IRG") at Chase which
work with the Monitoring Committee, Monitor, Grant Thornton, and others to ensure that Chase
meets its obligations under the terms of the National Mortgage.Settlement Agreement.

The Relator asserts that these individuals were provided information concerning the
population of RCV 1 which should have been included in testing to see if Chase was meeting its
servicing obligations under the terms of the National Mortgage Settlement Agreement.

Based on the email string from Tab 16 of the August 22, 2013 Government Presentation
Binder, it appears that they are aware of RCVl population of loans which were potentially
improperly submitted for consumer credits.