(15-00293 403-14) Ex 14 Schneider Deposition Ex. 139

Case 1:15-cv-00293-LTS-RWL Document 403-14 Filed 05/10/19 Page 1 of 9
([KLELW
'l
'1
From: P,atrick M Boyle [patrick.m.boyle@jpmchase.com]
~atrick
Sent: Wednesday, December 09, 2009 9:28 PM
To: Larry Schneider
L:~rry
Subject: RE:
RE: 1st
1st Lien
Lien Pool
Pool -- Eddie
Eddie Guerrero
Guerrero
'I
Appreciated the conversation this afternoon and look forward to talking to you in the future.
Mike
Mike Boyle
Vice-President, Loss Mitigation and Recovery
1820 E. Sky Harbor Circle S
S
Phoenix, AZ 85034
Mail Code AZl-2514
602-627-2489 (office)
602-910-3326 (fax)
From: Larry Schneider [mailto:Larry@sacapitalpartners.com] DEFENDANT’S

DEFENDANT'S
Sent: Wednesday, December 09, 2009 10:03 AM ) EXHIBIT
.EXHIBIT.
To: Patrick M Boyle
Subject: RE: 1st Lien Pool - Eddie Guerrero
i (31
131
Mike,
II tried you again this morning and left a voicemail although II believe you are working from a remote location today. I've
advised everyone in my office to personally inform me when you call so that we can finally speak.
just a few of the things I'd like to talk about which II believe are of great concern at the highest levels of Chase.
Here are Just
st
1. "1^‘ Lien Walks"
"1
a. Ongoing legislation to make lenders responsible for not taking steps to secure and maintain vacant and
blighted
blighted properties.
properties.
b. Collection
b. Collection Agencies
Agencies --1I believe
believe most
most of
of the 3rd party
the 3"‘‘ party agencies
agencies used
used by
by Chase
Chase are
are licensed
licensed to collect debt
to collect debt
in general but not specifically licensed to service mortgage loans on your behalf. This should be of
primary concern as this is potentially a front page Wall Street Journal article, class action borrower
lawsuit
lawsuit of
of unprecedented
unprecedented size,
size, and
and political
political mess
mess with
with the
the Department
Department of
of Housing
Housing and
and Urban
Urban
Development, especially in light of Chases' use of TARP funds.
c. The actual mortgages have little or no monetary value and most are vacant properties which are
draining resources that could be otherwise deployed towards collectable debt.
2. Bankruptcies
a. We used to acquire bankruptcy loans from chase but for about a year they were no longer available.
b. My understanding from Eddie was that there was approximately 15,000 loans that were just sitting in aa
queue and many loans in which Chase does not have the resources to even get a a proof of claim filed.
Most being Chapter 7 discharge loans either already foreclosed or on their way to being foreclosed.
SA00257000
:I
. ,1
Basically, we would
Bas;cally, wou Id 1;like take
ke to Je
I
allII of the 1"·uen
most or a lien walk and bankruptcy files off your hands ;in quick and
n a qukk
seamless manner such that Yl?ur your potential financial and political liability is immediately reduced and potential damage
to the Chase corporate public image is immediately minimized while simultaneously freeing up your available personnel
nd
resources to
resources concentrate on
to concentrate on the
the ever
ever increasing
increasing 2 2"'^ lien and
lien and loan
loan modification
modification debt collection activities.
debt collection activities.
We have existing master mortgage loan sale agreement in place which was created and approved by your legal
st
1^* lien pool sale. We do not require any due diligence and simply need someone to
department and utilized for the last 1
identify the queues relating to these accounts and have a spreadsheet generated with the name, address, loan number
and loan amount as the exhibit and this can essentially be closed in a
a day. Certainly for the end of the year. As II had
mentioned in a previous email, we have been one of the most active note sale buyers with Chase and have an excellent
working relationship with Launi Solomon and the entire support department. We will immediately prepare and record
every assignment and only request files from storage as needed.
Mike, this is a great opportunity for you to really clean things up over there at the "flip of a switch". II believe Mark Davis
nd
has been on board with the idea for a while and the hold up in having done a 2 bulk sale was the complexity of the
WAMU conversion. You really have a mess on your hands with all the potential liability. Please let me know what I can
do to help you consider and facilitate my proposal.
You'll
You'll be happy to
be happy to know
know II didn't
didn't leave
leave this
this proposal
proposal as
as message
message in
in your voicemail.
your voicemail.
Best regards,
Larry Schneider
From: Patrick M
M Boyle [mailto:patrick.m.boyle@jpmchase.com]
Sent: Tuesday, December 08, 2009 5:09 PM
To: Larry Schneider
No problem on "dem Cowboys". Understood.
II will try to ring you in the morning.
Mike
Mike Boyle
S
Phoenix,
Phoenix, AZ 85034
AZ 85034
Mail Code AZl-2514
CodeAZl-2514
602-627-2489 (office)
602-910-3326
602-910-3326 (fax)
(fax)
From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

Sent: Tuesday, December 08, 2009 2:56 PM
To: Patrick M
M Boyle
Subject: Re: 1st Lien Pool - Eddie Guerrero
Mike,
SA00257001
II feel
feel like
like an
an idiot thi
idiot about
about the Cowboys
Cowboys comment...
comment... II thought JefFMcGrane said
thought JeffMcGrane said you
you were
were based in Texas.
based in Texas.
I
Sorry for
Sorry for this
this back and forth
back and forth with
with the
the emails
emails and
and messages.
messages. I'm
I'm sure
sure we
we have
have both
both put
put together multi-million
together multi-million
dollar deals with half the effort. I've been in senseless meetings all day with compliance attorneys.
dollar deals with half the effort. I've been in senseless meetings all day with compliance attorneys.
I'll try
I'll try you in the
you in the morning and will
morning and will be
be avail.able
available all
all day
day and
and gave
gave the
the receptionist
receptionist instructions to put
instructions to put your
your call
call
through regardless.
through regardless.
Best regards,
Best regards,
Larry Schneider
Larry Schneider
Sent via
Sent via BlackBerry
BlackBerry by AT&T
by AT&T
From: Patrick
From: Patrick M
M Boyle <patrick.m.boyle@jpmchase.com>
Boyle <patrick.m.boyle@jpmchase.com>
Date: Tue, 8 Dec 2009
Date: Tue, 8 Dec 2009 09:36:21
09:36:21 -0500
-0500
To: Larry
To: Larry Schneider<Larry@sacapitalpartners.com>
Schneider<Larry@sacapitalpartners.com>
Subject: RE:
Subject: RE: 1st
1st Lien Pool -- Eddie
Lien Pool Eddie Guerrero
Guerrero
Morning
Morning Larry.
Larry.
Just left a message at your office. II am working off site tod~y,

today, and don't have a good number to give you to call me
back. Told the young lady on the phone that if you send me a couple time windows today/tomorrow II can try back.
As to the Cowboys, I am in Phoenix so aside from hating the Raiders and Broncos with aa passion, the Cowboys are third
on my list of "most hated" so your G-Men can beat up on them as much as they please. Nothing would make me
happier than seeing the Cowboys 0 for December yet again!
Now,
Now, you want to
you want talk Cardinals,
to talk Cardinals, and
and the
the spanking
spanking they
they laid
laid on
on a
a certain
certain NY team last
NY team last month? That is
month? That is something
something II am
am
more than happy to oblige!!
oblige! I
Have a good day and talk to you soon.
Mike
Mike Boyle
Mike Boyle
S
Phoenix, AZ 85034
Mail Code AZl-2514
602-627-2489 (office)
(office)
602-910-3326 (fax)
(fax)

Sent: Monday, December 07, 2009 6:07 PM
To: Patrick M
M Boyle
SA00257002
11
:l l
Hey Mike, :
II received your message this ;morning

orning and tried reaching you twice today but II didn't want to bother you with aa
voicemail as email is more efficient. "'I'll
I'll try you again on Tuesday morning as II will be out of the office in the afternoon.
Otherwise, please feel free to call me at your convenience if I'm unable to reach you first. II should disclose that II am aa
NY Giants fan and hope the recent Cowboys loss does not hurt my chances of getting aa deal done with you in the near
future...
future ...
Thanks again for your follow up.
Larry
M Boyle [mailto:patrick.m.boyle@jpmchase.com]
From: Patrick M
Sent: Friday, November 20, 2009 4:00 PM
To: Larry Schneider
Hey Larry. Sorry II was not able to reach out this week as it has been a bit more than chaotic all week.
I will try to reach out to you over the next few days as II will be in town and need only to carve aa bit of time. Will you be
around and accessible next Wednesday? If so, let me know a time or two and perhaps we can have a brief introductory
call at that time.
Thanks and have a great weekend.
Mike
Mike Boyle
Vice-President, Loss Mitigation
Circle S
1820 E. Sky Harbor Circles
Phoenix, AZ 85034
Code AZl-2514
Mail CodeAZl-2514
602-627-2489 (office)
602-910-3326 (fax)

M Boyle
To: Patrick M
Subject: FW: 1st Lien Pool - Eddie Guerrero
Mike,
st
Please let
Please let me
me know
know when it would
when it would be
be convenient
convenient for
for me
me to
to give
give you
you a
a call
call to discuss the 1
to discuss 1^* lien pool.
Thank you,
Larry Schneider
Mortgage Resolution Servicing
4
SA00257003
2101 NW
2101 NW Corporate
Corporate Blvd.,
Blvd., Suite
Suite 102
102
Boca Raton, FL 33431
Boca Raton, FL 33431 11
1
Tel: 561-893-9805
Tel: 561-893-9805x204
x 204
Fax:
Fax: 561-893-9808
561-893-9808 \
I
From: Larry Schneider

Sent: Tuesday, November 17, 2009 1:35 PM
M Boyle'
To: 'Patrick M
Mike,
II will be in the office all day Thursday and Friday and should be available anytime so please let me know what time is
convenient for you.
Eddie gave me the impression that getting the "1 "!'*st lien walks" off Chase's books before the end of the year was a top
priority at the highest levels of management due to potential liability issues and a a drain on resources for loans that have
little or no value. He had a preliminary list of several thousand notes generated but there were some problems with the
WAMU conversion
WAMU conversion so
so he
he was
was waiting for some
some internal
internal coding corrections
corrections to
to be
be made
made before
before he
he sent
sent over
over the list
list for my
my
review. Otherwise,
review. Otherwise, II believe
believe we
we were ready
ready to move
move forward.
II look
look forward
forward to
to working
working with
with you.
you.
Larry
Larry
Larry Schneider
Larry Schneider
2101 NW Corporate
2101 NW Corporate Blvd.,
Blvd., Suite
Suite 102
102
Boca Raton,
Boca Raton, FL
FL 33431
33431
Tel: 561-893-9805
Tel: 561-893-9805xx 204
204
Fax: 561-893-9808
Fax: 561-893-9808
From:
From: Patrick
Patrick M
M Boyle
Boyle [mailto:patrick.m.boyle@jpmchase.com]
[mailto:patrick.m.boyle@jpmchase.com]
Tuesday, November
Sent: Tuesday, November 17,17, 2009
2009 12:29
12:29 AM
Larry Schneider
To: Larry Schneider
Cc: Mark
Mark WW Davis
Davis
Mr. Schneider,
Mr. Schneider,
Mark Davis has passed your note along to me for review as II have recently been installed into the leadership role for our
recovery operations. II work directly with Mr. Paxton, and while I have not yet been brought up to speed on the
information you provided, I would like very much to touch base with you in the next few days where we can introduce
each other, talk through the process thus far, progress made, issues to consider, and next steps. Clearly II would like to
get a full understanding of the efforts that you had underway prior to Eddie's passing, and move forward as appropriate.
5 .
5
SA00257004
SA00257004
I am actually traveling through Wednesday of this week but will be back in my Phoenix office Thursday and Friday. If you
have some time either, day, perhaps we can schedule a bit of time to get started? Let me know a couple of times that
might work for you, and we can go from there.
II look
look forward to our
forward to our convers~tion.
conversation.
■ I
Mike
Mike
Mike Boyle
Boyle
Vice-President, Loss Mitigation/Recovery
1820 E. Sky Harbor Circle
CirclesS
Phoenix, AZ
Phoenix, AZ 85034
Mail Code AZl-2514
Mail Code
602-627-2489 (office)
602-910-3326 (fax)
From: Mark W Davis

Sent: Monday, November 16, 2009 4:07 PM
To: Patrick M
M Boyle
FYl
FYI

To: Mark W Davis
To: ·
Cc: Chad GG Paxton
Subject: 1st Lien Pool - Eddie Guerrero
Dear Mr. Davis and Mr. Paxton,
st
Early this year Eddie Guerrero and Victor Fox had put together a 1 1®* lien pool which consisted of "problem loans" that
Chase wanted off their books and more importantly out of their name due to the bad press and potential liability
associated with these loans which are mostly situated in urban areas. Our related entities have been note sale buyers
with Chase (BankOne) for almost seven years and we are prepared to make this next transaction as seamless as the prior
deal and Chase can expect the same level of professionalism and accountability from our firm in the acquisition of this
st
new 11^* lien pool. We never sell any of our loans and we understand that Chase has a fiduciary responsibility to make
sure that any loans owned by Chase are sold to a reliable and competent company that can properly manage and service
these loans. Eddie Guerrero and II had worked closely together for many years and he was attempting to finalize the
bulk sale of another similar pool to our firm before his passing last week.
Please note some of the information below as to the time, resources and cost incurred by our firm to ensure that the
transfer of these problem loans are as seamless, immediate and cost effective as possible for Chase.
Chase ..,
•• Approximately 1,000 loans were pulled from the pool after our initial offer was accepted.
•• Approximately 100 loans were later identified as by Chase as "fraud loans" which we immediately agreed to
give back to Chase without question.
•• We've incurred hundreds of thousands of dollars in title search reports to determine which loans were actually
still secure eliminating the need to prepare assignments or request files from Chase's vault unnecessarily.
SA00257005
:1
ii
• Approximately 2/3 of the loans sold to us were coded incorrectly and turned out to be mortgage deficiencies
(Homesales) foreclosures and not secured mortgages. We will again spend the resources necessary
from Chase (Homes~les)
to make those determinations.
• Our firm prepared all of the approximately 1,500 Assignments of Mortgage saving Chase the cost of
$225,000.00 ($150.00 each normally charged by Cherin & & Yelsky) but more importantly saved Chase the time
and resources required to handle the coordination of such.
• We've spent hundreds of thousands of dollars in legal fees and thousands of man hours working hand in hand
with local municipalities to assign, satisfy and foreclose on nuisance properties.
• We have agreed to accept al.almost
m ost any payment arrangement or loan modification proposed by borrowers to
keep them in their properties.
As you know, these are very challenging loans on mostly low value, vacant and dilapidated properties that require
immediate action to protect the interests, credibility and public image of both Chase and our firm. It is also imperative
to expedite the closing of this note sale in order to winterize many of these properties as many Northern areas of the
Country will soon be experiencing freezing temperatures which often burst pipes and creates even more problems for
these properties.
Upon receipt of a a data tape, we will need approximately one week for due diligence to do a random sampling of the
pool, then again make a nominal offer for whatever loans are in the pool, whether secure or unsecure under the same
terms of "no buybacks for any reason whatsoever" and "any loan needed to be pulled back by Chase agreed to for any
reason whatsoever". A copy of the prior Note Sale Agreement prepared by the legal department at Chase and executed
by Victor Fox is enclosed.
Upon approval, we are able to upload the basic customer property information and have RESPA Notification of Loan
Transfer letters out to all corresponding borrowers within twenty-four (24) hours of acceptance. We have worked very
closely with Launi Solomon and her team in Loss Mitigation Support and look forward to working with her again. We
encourage you to please ask her forfpr a reference. We have the knowledge, resources and servicing platform available to
immediately absorb up to 5,000 loans.
Please let me know who my point of contact will be so we can proceed with the transaction.
Sincerely,
Larry Schneider
2101 NW Corporate Blvd., Suite 102
FL 33431
Boca Raton, FL 33431
Tel: 561-893-9805 x 204
Tel: 561-893-9805x204
Fax: 561-893-9808
Fax: 561-893-9808
This communication is for informational purposes only. It is not intended as an offer or solicitation for the
purchase or sale of any financial instrument or as an official confirmation of any transaction. All market prices,
data and other information are not warranted as to completeness or accuracy and are subject to change without
notice. Any comments or statements made herein do not necessarily reflect those of JPMorgan Chase & Co., its
subsidiaries and affiliates. This transmission may contain information that is privileged, confidential, legally
privileged, and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are
hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including
any reliance thereon) is STRICTLY PROHIBITED. Although this transmission and any attachments are
believed to be free of any virus or other defect that might affect any computer system into which it is received
and opened, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted
by JPMorgan Chase & Co., its subsidiaries and affiliates, as applicable, for any loss or damage arising in any
7
SA00257006
SA00257006
• way
way from
from its
its use. If you
use. If you reLved this transmission
received this transmission inin error, please immediately
error, please immediately contact
contact the
the sender
sender and
and destroy
destroy
the material in its entirety, whether in electronic or hard copy format. Thank you. Please refer to
the material in its entirety, Whether in electronic or hard copy format. Thank you. Please refer to
http://www.jpmorgan.com/pages/disclosures for
http://www.jpmorgan.com/pages/disclosures for disclosures
disclosures relating to European
relating to European legal
legal entities.
entities.
This communication
This communication is is for
for informational
informational purposes only. It
purposes only. It is
is not
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an offer
offer or
or solicitation
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the
notice. Any
notice. Any comments
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JPMorgan Chase Chase & & Co.,
Co., its
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SA00257007
SA00257007

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Case 1:15-cv-00293-LTS-RWL Document 403-14 Filed 05/10/19 Page 1 of 9

From: Larry Schneider [mailto:Larry@sacapitalpartners.com] DEFENDANT’S

No problem on "dem Cowboys". Understood.

II will try to ring you in the morning.

From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

Just left a message at your office. II am working off site tod~y,

Have a good day and talk to you soon.

From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

II received your message this ;morning

Thanks again for your follow up.

Thanks and have a great weekend.

From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

From: Larry Schneider

From: Mark W Davis

From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

Dear Mr. Davis and Mr. Paxton,

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