Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 1 of 16

EXHIBIT 3
 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 2 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 ·

·1· · · · · · ·UNITED STATES DISTRICT COURT

·2· · · · · · ·SOUTHERN DISTRICT OF NEW YORK

·3

·4· ·- - - - - - - - - - - - - - - -x

·5· ·MORTGAGE RESOLUTION SERVICING,

· · ·et al.
·6
· · · · · · · · ·Plaintiff,· · · · Case Number:
·7· · · · · · · · · · · · · · · · ·15-CV-00293-LTS-JCF

·8· · · · vs.

·9· ·JPMORGAN CHASE, N.A., et al.

10· ·- - - - - - - - - - - - - - - -x

11· · · · · · · · · · · · Raleigh, North Carolina

12· · · · · · · · · · · · Friday, January 12, 2018

13

14· · · · · · · ·DEPOSITION OF VICTOR B. FOX, a

15· ·witness herein, called for examination by counsel

16· ·for the Plaintiffs, in the above-entitled matter,

17· ·pursuant to Subpoena and Notice, the witness

18· ·being duly sworn by VIRGINIA E. LEWIS, a Notary

19· ·Public in and for the State of North Carolina,

20· ·taken at Fayetteville Street Executive Suites,

21· ·Suite 201, 555 Fayetteville Street, Raleigh,

22· ·North Carolina, at 9:54 a.m., on Friday, January

23· ·12, 2018, and the proceedings taken down by

24· ·Stenotype by VIRGINIA E. LEWIS, transcribed under

25· ·her direction.

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 3 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 13

·1· ·June 2009?

·2· · · · · ·MR. SOUKUP:· Object to form.
·3· · · · · ·Go ahead and answer that.
·4· · · A.· ·No, it's not accurate.· I haven't been in
·5· ·my LinkedIn file in, gosh, I don't know how long,
·6· ·and didn't put it as a representation of my full
·7· ·career, not like a resume.· It's simply updates
·8· ·of positions that I had.
·9· · · Q.· ·Okay.· What additional positions would
10· ·you add from 1999 to the present that are not
11· ·represented here?
12· · · A.· ·My time at Chase.
13· · · Q.· ·Okay.· And when was that?
14· · · A.· ·It was, approximately, March or April of
15· ·2008 through June of 2009.
16· · · Q.· ·Okay.· So, March of 2008 to June 2009.
17· · · · · ·If we added that to this selection here
18· ·between 1999 and the present, would that be an
19· ·accurate representation of your time during that
20· ·time period, of your work experience during that
21· ·time period?
22· · · A.· ·No.· I would also put in the time that I
23· ·worked with Collect Com Credit in Canada.
24· · · Q.· ·Okay.· And how long were you with Collect
25· ·Com Credit?

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 4 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 16

·1· · · Q.· ·What is a charge-off?

·2· · · A.· ·Any account that reaches the contractual
·3· ·limits and needs to be moved off of a servicing
·4· ·system onto another accounting system.
·5· · · Q.· ·Did you participate in the decision to
·6· ·move an account from ordinary servicing to the
·7· ·charge-off system?
·8· · · A.· ·Could you repeat that?
·9· · · Q.· ·It's a bad question.· I'll try a little
10· ·harder.· Was it your position to decide when an
11· ·account had failed to meet the contractual
12· ·obligations and, therefore, needed to be moved
13· ·from the servicing over to the recovery platform?
14· · · · · ·MR. SOUKUP:· Object to form.
15· · · · · ·You can go ahead and answer.
16· · · · · ·THE WITNESS:· Okay.
17· · · A.· ·No.· They were systemic.
18· · · Q.· ·Did you participate in the creation of
19· ·the systems that made that decision?
20· · · A.· ·No.
21· · · Q.· ·Were those systems in place when you
22· ·joined Chase?
23· · · A.· ·Yes.
24· · · Q.· ·Did they change during your time at
25· ·Chase?

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 5 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 30

·1· ·because they had been foreclosed on?

·2· · · A.· ·I believe so.
·3· · · Q.· ·Okay.· In your years working in
·4· ·collections, have you worked in systems where, or
·5· ·similar systems in other banks where a loan went
·6· ·into the equivalent of a recovery department and
·7· ·then went back into good standing and was removed
·8· ·from that recovery department back to an ordinary
·9· ·line of information -- system?· I apologize.
10· · · A.· ·Not to the best of my knowledge, no.
11· · · Q.· ·Okay.· In Chase, did loans that were paid
12· ·up to date ever leave recovery to go back to an
13· ·ordinary servicing system?
14· · · A.· ·Not to my knowledge.
15· · · Q.· ·What would happen to a homeowner who paid
16· ·up all their past due?· Would the charge-off be
17· ·removed?
18· · · · · ·MR. SOUKUP:· Object to form.
19· · · A.· ·That's not my expertise because that's
20· ·credit bureau reporting, and I --
21· · · Q.· ·So, you have no understanding of that?
22· · · A.· ·Correct.
23· · · Q.· ·Okay.· Do you have mortgage servicing
24· ·experience in the years that you've worked in
25· ·banking?

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 6 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 31

·1· · · A.· ·Yes.

·2· · · Q.· ·And what is that experience, sir?
·3· · · A.· ·Running escrow payment processing,
·4· ·exception payment processing.
·5· · · Q.· ·Was there any type of servicing that was
·6· ·done within the recovery department that you
·7· ·supervised?
·8· · · A.· ·No.
·9· · · Q.· ·When loans came into the recovery
10· ·department that were in first --
11· · · A.· ·(Witness indicating.)
12· · · Q.· ·Please.
13· · · A.· ·One second, please.· I'll go back to the
14· ·other one.· Do you mean in my time in my career
15· ·or at Chase?
16· · · Q.· ·At Chase.
17· · · A.· ·Oh, I'm sorry.· Could you please repeat
18· ·that question?
19· · · Q.· ·Yes.· I'll ask the stenographer to see if
20· ·she can do that.
21· · · · · ·(Record read.)
22· · · Q.· ·Okay.· Was any type of servicing done to
23· ·the loans which came into the recovery department
24· ·at Chase?
25· · · A.· ·Not that I remember.

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 7 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 32

·1· · · Q.· ·Okay.· When a loan came to the recovery

·2· ·department at Chase that was a first closed-end
·3· ·loan, was there any type of work done to address
·4· ·escrow issues with the loan?
·5· · · A.· ·To the best of my knowledge, not within
·6· ·the recovery group.
·7· · · Q.· ·Okay.· If a loan was assigned to
·8· ·recovery, aside from the foreclosure line of
·9· ·action we discussed earlier, do you understand
10· ·whether or not there were other departments also
11· ·working on that loan?
12· · · A.· ·I believe so.
13· · · Q.· ·Okay.· Do you know the names of those
14· ·other departments?
15· · · A.· ·No, sir.
16· · · Q.· ·So, it was your understanding that once
17· ·a loan was in recovery, it could not be placed
18· ·back into ordinary servicing; is that correct?
19· · · A.· ·That is my understanding.
20· · · Q.· ·Did the software in recovery allow you to
21· ·establish the daily interest rate that the loan
22· ·was accumulating?
23· · · A.· ·I don't remember.
24· · · Q.· ·Do you recall how interest was calculated
25· ·on recovery loans?

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 8 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 40

·1· ·the East Coast.

·2· · · Q.· ·Okay.· Did the recovery system only
·3· ·include secured loans?
·4· · · A.· ·I would say no, because it housed all
·5· ·charged-off loans, or the bulk of the charged-off
·6· ·loans, so --
·7· · · Q.· ·Okay.· When a loan is charged off, does
·8· ·that mean that it's not secured?
·9· · · A.· ·No, not by definition.
10· · · Q.· ·Okay.· So, why do you associate the fact
11· ·that they are charged off with whether or not the
12· ·recovery system had only secured loans or did not
13· ·have only secured loans?
14· · · A.· ·Because you could have post-foreclosure
15· ·loans going in, you could have deficiency
16· ·balances going in; so, you could have unsecured
17· ·loans in there.
18· · · Q.· ·Okay.· Was there a system for separating
19· ·secured loans from unsecured loans in recovery?
20· · · A.· ·I can't remember what the queue setups
21· ·were and whether you could identify and split the
22· ·loans.
23· · · Q.· ·Okay.· In your work in banking, was it
24· ·important for you -- strike that.
25· · · · · ·During your time at Chase, was it

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 9 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 83

·1· · · A.· ·Say your question one more time, please?

·2· · · Q.· ·Okay.· As a business matter, you executed
·3· ·this document on behalf of Chase, correct?
·4· · · A.· ·Yes.
·5· · · Q.· ·And in executing it, you wanted to make
·6· ·sure that everything in it was accurate, correct?
·7· · · A.· ·(No response.)
·8· · · Q.· ·Let's try it this way, Mr. Fox.
·9· · · · · ·Before executing this document, as a
10· ·matter of practice, would you have sought
11· ·confirmation from someone within Chase that all
12· ·conditions within it that were obligations of
13· ·Chase could be met?
14· · · A.· ·I can't remember all the steps that were
15· ·involved in this transaction and the sale of the
16· ·loans.
17· · · Q.· ·Is it your practice to execute a document
18· ·without knowing that the company you're
19· ·representing cannot meet the conditions?
20· · · A.· ·No, it is not my practice.
21· · · Q.· ·Okay.· Would it have been your practice
22· ·to confirm that the company you were representing
23· ·here could meet all its conditions?
24· · · A.· ·Specific to this transaction, it's my
25· ·understanding everyone knew what they were

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 10 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 84

·1· ·getting.
·2· · · Q.· ·So, what's written is unimportant?
·3· · · · · ·MR. SOUKUP:· Object to form.
·4· · · A.· ·No, I'm not saying it's unimportant.
·5· · · Q.· ·Okay.· What's written is not the final
·6· ·deal?
·7· · · · · ·MR. SOUKUP:· Object to form.· I don't
·8· ·know how Mr. Fox can make that legal conclusion.
·9· · · Q.· ·Well, sir, when you signed it, did you
10· ·believe that it contained all the business issues
11· ·that needed to be set forth in completing the
12· ·transaction?
13· · · · · ·MR. SOUKUP:· Object to form.
14· · · A.· ·When I signed it, I believe it was
15· ·completing the sale of the loans to
16· ·Mr. Schneider's group.
17· · · Q.· ·Okay.· And did you believe that Chase
18· ·could meet all the conditions that were contained
19· ·within this document?
20· · · A.· ·Say that again?
21· · · Q.· ·Did you believe that Chase could meet all
22· ·its obligations contained in this document?
23· · · · · ·MR. SOUKUP:· Object to form, foundation.
24· · · A.· ·I would say yes.
25· · · Q.· ·Okay.· Did you believe upon signing it

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 11 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 90

·1· · · A.· ·Validated in the general term that the

·2· ·loans were sent.
·3· · · Q.· ·Okay.· Do you know who Launi Solomon was?
·4· · · A.· ·I remember the name.
·5· · · Q.· ·Do you remember whether she was someone
·6· ·who worked within recovery?
·7· · · A.· ·I can't remember.
·8· · · Q.· ·Okay.· Do you recall whether or not the
·9· ·loan pool was put out to bid?
10· · · A.· ·I don't believe it was, because it was
11· ·basically a one-off transaction, but I don't
12· ·recall with any certainty if we put it out for
13· ·bid.
14· · · Q.· ·Okay.· You stated earlier that you would
15· ·have had the authority, as you understood it, to
16· ·sign this document?
17· · · A.· ·Correct.
18· · · Q.· ·Okay.· Where would you have received the
19· ·authority to sign this document?
20· · · A.· ·I can't remember if Chase published
21· ·delegated lines of authority or how that would --
22· ·or if it was at the organizational level,
23· ·functional level; I don't remember.
24· · · Q.· ·Who was your supervisor at Chase?
25· · · A.· ·Mark Davis.

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 12 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 92

·1· ·something, but not meet with anyone.

·2· · · · · ·(Plaintiffs'(Fox) Exhibit No. 9 was
·3· ·marked for identification.)
·4· · · Q.· ·You have been handed what's been marked
·5· ·as Exhibit 9.· It's Bates numbered as
·6· ·JPMC-MRS-0000342 through 3426.· Please take some
·7· ·time and review the document, sir.
·8· · · A.· ·(Perusing document) Okay.
·9· · · Q.· ·Do you recall receiving this e-mail
10· ·string?
11· · · A.· ·Well, I'm reading it, so, yeah, it's
12· ·brought back some memory, yeah.
13· · · Q.· ·Okay.· And what is the memory that it's
14· ·brought back?
15· · · A.· ·That Larry's group wanted to purchase
16· ·these loans.· They did all the leg work on it,
17· ·they did the due diligence on it, and wanted to
18· ·pay a nominal fee for them, and -- well, I think
19· ·it's in here.· I think we settled up at two
20· ·hundred thousand or something for the pool of
21· ·loans.
22· · · Q.· ·Looking at the top of the first page, No
23· ·one other than us will review it based on his
24· ·finding.· I don't think it is worth marketing.
25· · · · · ·What do you mean by it is not worth

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 13 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 93

·1· ·marketing?
·2· · · A.· ·What I meant by that is I wouldn't put
·3· ·this out for bid.
·4· · · Q.· ·Okay.· Why?
·5· · · A.· ·Based on the findings of Larry's
·6· ·research.
·7· · · Q.· ·Okay.
·8· · · A.· ·It was -- just reading that, I remember
·9· ·its very detailed research, and I would venture
10· ·to say they looked at every single loan in there.
11· · · Q.· ·And how many loans were in there?
12· · · A.· ·I have no idea.· I didn't total up the --
13· · · Q.· ·Looking at page 3424 at the bottom of the
14· ·first paragraph, end of the line --
15· · · A.· ·Um-hmm.
16· · · Q.· ·-- do you see where he states number of
17· ·loans?
18· · · A.· ·Yes.· Well, he states a couple of
19· ·different variations of pockets of loans.· This
20· ·one is just addressing 2,300 in excess of a
21· ·hundred and ten million.
22· · · Q.· ·Well, I'm just looking at the end of the
23· ·first line, "keeping 6,000 loans organized."
24· ·Do you see that where he says that at the end of
25· ·the first paragraph?

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 14 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 102

·1· · · · · ·When did you inform Mr. Schneider that he

·2· ·needed to deliver payment?
·3· · · A.· ·I don't recall.
·4· · · Q.· ·Do you recall when he delivered payment?
·5· · · A.· ·No, I don't.
·6· · · Q.· ·Okay.· Based on Exhibit 10, looking at
·7· ·the e-mail chain that you have there in his
·8· ·statement, when did he send that e-mail?· Do you
·9· ·have a date on that?
10· · · A.· ·That would have been 12/10.
11· · · Q.· ·Okay.· So, on 12/10 it appears that he
12· ·had a check for $200,000 cut already.· Is that an
13· ·accurate statement?
14· · · A.· ·Based on his e-mail, yes.
15· · · Q.· ·Okay.· Do you recall when the bank
16· ·received that check?
17· · · A.· ·No, I do not.
18· · · · · ·(Plaintiffs'(Fox) Exhibit No. 11 was
19· ·marked for identification.)
20· · · Q.· ·I'm going to hand you what's been marked
21· ·as Exhibit 11.· It has a Bates number of
22· ·JPMC-MRS-00003179 through 3181.· Please take some
23· ·time to look at it.
24· · · A.· ·(Perusing document) Okay.
25· · · Q.· ·Does this refresh your recollection as to

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 15 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 103

·1· ·when you received payment from Mr. Schneider?

·2· · · A.· ·The exact date?· No, but it looks like it
·3· ·came in sometime in December.
·4· · · Q.· ·Sometime in December you would have
·5· ·received the payment?
·6· · · A.· ·It looks like that, yes, based on the
·7· ·dates of the e-mails.
·8· · · Q.· ·If the e-mail is accurate and you
·9· ·received the payment sometime in December, what
10· ·would you have done with that payment?
11· · · A.· ·I don't know if it was posted right away
12· ·or not.
13· · · Q.· ·Okay.· Was there a process for receiving
14· ·payments on loans?· Strike that.· Was there a
15· ·process for receiving payments on loan purchases?
16· · · A.· ·To the best of my knowledge, this was a
17· ·one-off pool loan, so this was new.· And I don't
18· ·recall what the steps were in, you know,
19· ·finishing this out.· On the one-off note sales,
20· ·I'm not sure of how that was handled either, how
21· ·the money was moved in, if it was an electronic
22· ·transfer or physical check coming in.
23· · · Q.· ·Okay.· When a loan is sold, is the
24· ·payment received by Chase applied to the
25· ·outstanding principal of the loan or is it

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 Case 1:15-cv-00293-LTS-RWL Document 427-3 Filed 09/30/19 Page 16 of 16
MORTGAGE RESOLUTION SERVICING, et al. vs. JPMORGAN CHASE, N.A., et al. DEPOSITION OF
VICTOR B. FOX on 01/12/2018 Page 121

·1· ·closing this deal?

·2· · · A.· ·I don't understand commission.
·3· · · Q.· ·A commission for the sale on the $200,000
·4· ·collected.
·5· · · A.· ·I don't know.
·6· · · Q.· ·Would it surprise you if there was a
·7· ·bonus paid?
·8· · · A.· ·I really couldn't answer yea or nay on
·9· ·that.
10· · · · · ·MR. DI MARCO:· All right.· Let me take a
11· ·few minutes to chat with my client, and we may be
12· ·close.
13· · · · · ·MR. SOUKUP:· Okay.· We may have a few
14· ·documents to ask him about, but we'll be done in
15· ·less than five minutes, I hope.
16· · · · · ·MR. DI MARCO:· Sure.
17· · · · · ·(Recess taken.)
18· · · · · ·(Plaintiffs'(Fox) Exhibit No. 15 was
19· ·marked for identification.)
20· · · Q.· ·I'm going to hand you a document marked
21· ·as Exhibit 15 and ask you what it is?
22· · · A.· ·It's a cashier's check drawn on Northern
23· ·Trust, N.A. for $200,000.
24· · · Q.· ·And who's it paid to?
25· · · A.· ·Chase Home Finance.

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