Case 1:15-cv-00293-LTS-RWL Document 154-17 Filed 03/14/17 Page 1 of 5

Exhibit Q
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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
-------------------------------- x
S & A CAPITAL PARTNERS, INC., et al., :
:
Plaintiffs, : No. 15-cv-00293-LTS-JCF
:
- against - : NOTICE OF DEPOSITION
:
JPMORGAN CHASE BANK, N.A., et al., :
:
Defendants. :
-------------------------------- x

PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil

Procedure, Plaintiffs, through their attorneys Chaitman, LLP, will take the deposition on oral

examination commencing at 10:00 a.m. on May 10, 2016, and at any adjourned date or time, at the

offices of Chaitman LLP, 465 Park Avenue, New York, New York 10022, of a witness (or

witnesses), designated by Defendants, who is (or are) most knowledgeable and prepared to testify

concerning the subject matter outlined in the Third Amended Complaint, and location of

documents and information responsive to the discovery demands and responses exchanged

between the parties, including, specifically, the following subject matter:

(a) Where and how particular categories of documents are located, stored and maintained,
including but by no means limited to documents in reference to

a. the plaintiffs
b. communications between Defendants or anyone acting on their behalf, and the
borrowers of loans Defendants sold to the plaintiffs
c. Defendants’ System of Records, including but not limited to the Vendor Lending
System and Mortgage Servicing Program or Platform, both active and inactive
d. All Recovery One (“RCV1”) databases and/or Recovery One “Applications”, both
active and inactive
e. the assessment and/or selection of loans to be included on Exhibit A to the MLPA
between the parties
f. Data tapes listing loans sent to Defendants on or around October 2008 through
February 2009, and the choice of which loans were included on such data tapes
g. Reasons why the data tapes did not include all requisite data such as borrowers’
names and addresses

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h. attempts to supply borrower information and files regarding the loans available for
sale to Plaintiffs
i. servicing of loans prior to their sale to Plaintiffs
j. the status of the loans sold to Plaintiffs at any time
k. any deviation from law, regulation, guideline or policy in servicing loans
l. Plaintiffs’ request for assignments of the notes and mortgages
m. payments received by Defendants on the loans after their sale
n. statements that Defendants were “recalling” certain loans
o. communications that certain loans were “deficiencies” including internal
documents relating to status of the loans
p. communications with Patrick Boyle regarding conversations regarding Defendants’
potential liability regarding defaulted loans on December 9, 2009
q. “forgiven loans that had previously been sold to others,” including “all
correspondence, both internal and external”
r. release of liens on properties pursuant to the “Pre-DoJ Lien Release Project” as
described in the Third Amended Complaint
s. communications with, and files sent to and received from third party collection
agencies regarding the loans
t. communications and recordkeeping regarding the RMBS settlement and National
Mortgage Settlement and Consent Judgment

(b) Defendants’ document retention policy

(c) How data is collected, stored, maintained and deleted

(d) Document retrieval processes

(e) Litigation hold procedures

(f) What is stored in individual custodians’ files, as specified in Defendants’ Responses

and Objections to Interrogatories

(g) The identity of potential additional custodians

(h) Policies and procedures regarding electronic records management

(i) Policies and procedures regarding employee use of company computers and data,
including but not limited to:

a. Desktop computers
b. Laptop computers
c. Home-based computers used for company business or communication purposes

(j) Computers currently in use and no longer in use, including:

a. Number, types and locations

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b. Operating systems with versions, dates of use and upgrade history

c. Application software with versions, dates of use and upgrade history

(k) Network architecture including

a. Network topology
b. File-naming conventions
c. Location-saving conventions
d. Disk or tape labeling conventions

(l) Company Email Systems and Instant Messaging Systems

(m) Company Intranets

(n) Onsite and Off-site Servers

(o) Off-site Escrow Services

(p) Archival Systems and Procedures, including disk, tape, or other media

(q) Backup Procedures, Inventories and Schedules, including Tape Reuse Cycles

(r) Disaster Recovery Systems, including power source, capacity and location

(s) Instances of computer or systems failures and subsequent data recovery efforts

(t) Online (third party hosted) repositories

(u) Portable devices,

(v) Document Management Systems

(w) Company Database and Systems Administration

PLEASE TAKE FURTHER NOTICE that the above-noticed deposition will be conducted
before a court reporter, notary public, or other person duly authorized to administer oaths under
the Federal Rules of Civil Procedure and the Local Civil Rules for the Southern District of New
York. The oral examinations will be recorded by stenographic and videographic means, and will
continue from day to day until complete.

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 Case 1:15-cv-00293-LTS-RWL Document 154-17 Filed 03/14/17 Page 5 of 5

Dated: April 20, 2016 /s/ Helen Davis Chaitman

New York, New York Helen Davis Chaitman
Chaitman LLP
465 Park Avenue
New York, New York 10022
Phone: (888) 759-1114

Attorneys for Plaintiffs

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