RED HERRINGS, MOLES & A FEISTY ORAL ARGUMENT BY HOMEOWNER-TRANSCRIPT

8/3/2019 RED HERRINGS, MOLES & A FEISTY ORAL ARGUMENT BY HOMEOWNER-TRANSCRIPT

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12 UNITED STATES BANKRUPTCY COURT3 DISTRICT OF DELAWARE

4 - - - - - - - - - - - - - - - - - - - - -x5 In the Matter of:6 NEW CENTURY TRS HOLDINGS, INC., et al., Case No.7 Debtors. 07-10416 (KJC)8 - - - - - - - - - - - - - - - - - - - - -x9 ANITA B. CARR, Plaintiff,10 - against - Adv. Proc. No.11 NEW CENTURY TRS HOLDINGS, INC., Defendant. 09-52251 (KJC)12 - - - - - - - - - - - - - - - - - - - - -x1314 U.S. Bankruptcy Court15 824 North Market Street16 Wilmington, Delaware

1718 July 26, 201119 11:12 AM2021 B E F O R E:22 HON. KEVIN J. CAREY

23 U.S. BANKRUPTCY JUDGE2425 ECR OPERATOR: AL LUGANO


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12 Status Conference Re: Motion of W. Mark Frazer and Konilynn3 Frazer, Pro Se to Allow Late Filing of Proof of Claim

45 Status Conference Re: Motion of Kimberly S. Cromwell, Pro Se6 to Consider Proof of Claim Timely Filed78 Oral Argument: Anita B. Carr v. New Century TRS Holdings,9 Inc., et al. (Adv. Pro. No. 09-52251): Motion for10 Reconsideration, Memorandum of Points and Authorities in11 Support; and Request for Clarification of the 2008 Motion for12 Relief from Stay13141516

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232425 Transcribed by: Sharona Shapiro


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12 A P P E A R A N C E S :3 BLANK ROME LLP

4 Attorneys for New Century Liquidating Trust5 BY: DAVID CARICKHOFF, ESQ.678 HAHN & HESSEN LLP9 Attorneys for New Century Liquidating Trust10 BY: EDWARD L. SCHNITZER, ESQ. (TELEPHONICALLY)111213 LAW OFFICES OF JOSEPH J. BODNAR14 Attorneys for The Guintos and Kimberly Cromwell and15 proposed counsel for the Frazers16 BY: JOSEPH J. BODNAR, ESQ.

171819 LESLIE MARKS (TELEPHONICALLY)20 Party Pro Se2122

23 ANITA B. CARR (TELEPHONICALLY)24 Party Pro Se25


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12 KIMBERLY CROMWELL(TELEPHONICALLY)3 Party Pro Se

456 MARK FRAZER (TELEPHONICALLY)7 Party Pro Se8910 RALPH WHITE(TELEPHONICALLY)11 Party Pro Se121314 ALSO PRESENT:15 ALAN M. JACOBS, Trustee, New Century Liquidating Trust16

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NEW CENTURY TRS HOLDINGS, INC., et al. 5

1 P R O C E E D I N G S2 THE COURT: Good morning everyone. I apologize for3 the delay.

4 MR. CARICKHOFF: Thank you, Your Honor. Good morning.5 May it please the Court. David Carickhoff of Blank Rome on6 behalf of the New Century Liquidating Trust.7 Your Honor, my co-counsel had tried to come down this8 morning. Due to some trains delays on their way down they9 decided rather than delay the Court with the train schedule10 that was going to cause them to be late, they headed back to11 their offices and are participating by phone. So they do12 apologize that they're not here in person for the hearing.13 If I could just quickly run through the agenda.14 Items 1 through 8 have either been continued or15 resolved, subject to certain things, documentation or getting16 additional things. Items number 9 through 13 are under

17 advisement. Items 14 and 15 are status conferences. And item18 number 16 is oral argument on the Carr Motion for19 Reconsideration. If we could just start with items 14 and 15,20 and with that I'd like to turn it over to my co-counsel?21 THE COURT: Mr. Carickhoff, I do have a question about22 number 8. The status line on the agenda indicates that the

23 Whites have requested a status conference for September 27.24 Can you tell me a little more about that?25 MR. SCHNITZER: Your Honor, it's Edward Schintzer from


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1 Hahn & Hessen on behalf of the Trust.2 Your Honor, I've had a conversation recently with Mr.3 White. The reason for that request was the following. What

4 was before this Court or would be before this Court at some5 point was Mr. White's -- their motion to compel certain6 discovery. Mr. White reached out to me and we are in a7 dialogue concerning that motion. He is going to get me8 information in a couple weeks, hopefully with the goal of9 resolving the motion consensually.10 So based upon that, Mr. White requested to adjourn his11 motion from today's calendar. It next would have been on12 August. I then asked that we could do it September instead.13 The reason was that the next omnibus hearing you have in August14 I will be on vacation that week so I would not be able to15 appear in person so I asked Mr. White if it was fine to move16 that to September, again, with the goal that we would be able

17 to resolve the discovery motion before you and then hopefully18 you not have to hear that motion.19 THE COURT: Okay. Thank you. Okay. You may proceed.20 MR. SCHNITZER: Your Honor, the other two matters that21 were on today are with respect to Cromwell and Frazer. These22 are status conferences that have been before the Court

23 regularly. As I recall from the last time we were before you,24 one of the questions was if there was going to be any25 additional briefing with respect to, I guess we'll call it not


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1 exactly the direct merits of the claim but the timeliness to2 the claim. So as I recall, we were during the last status3 conference, to come before you again today with respect to that

4 which I believe was a request by Mr. Bodnar with respect to5 perhaps additional briefing.6 Otherwise what I believe these matters are on for is7 they are on for at some point to have a date scheduled for the8 matters to go to trial because discovery is complete in these9 matters and really the only thing other than the timing is --10 actually the only other thing at issue is the merits or lack11 thereof of the underlying claims.12 THE COURT: All right. Mr. Bodnar?13 MR. BODNAR: Good morning, Your Honor. For the14 record, Joseph J. Bodnar on behalf of the Guintos, Kimberly15 Frazer -- Kimberly Cromwell, excuse me. And with respect to16 the Frazers, I had explained to the Court before that they

17 would on the phone and that that representation -- there was an18 issue raised by the trustee's counsel with respect to whether19 or not we needed approval of my representation of them from the20 Washington bankruptcy court, Your Honor. So Mr. Frazer is on21 the phone as well and can give an update with respect to that22 litigation.

23 THE COURT: Well, we're here on Frazer and Cromwell,24 not --25 MR. BODNAR: Correct.


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1 THE COURT: -- not Guinto?2 MR. BODNAR: Yes.3 THE COURT: Okay. So are you telling me you represent

4 the Frazers or you don't represent the Frazers?5 MR. BODNAR: Your Honor, as I had explained before on6 the record, I have an engagement letter that says that we would7 take whatever action was necessary to get approval from the8 bankruptcy court in Washington, if necessary. And I provided9 the Liquidating Trustee with some information with respect to10 the status of that matter.11 THE COURT: What's the status?12 MR. BODNAR: The status of that matter is that the13 trustee in Washington has said that they have no interest in14 pursuing with the Frazer's claims here and had put a record of15 that on the docket. I think they referred to them as docket16 text entries. And when I presented that to -- I believe my

17 last conversation on that subject was with Mr. Indelicato, he18 sort of shrugged his shoulders and said he didn't know if that19 was sufficient. I said well, I don't know what else I can give20 you at this moment. That's what they placed on the docket.21 They have advised Mr. Frazer that they had no interest in22 pursuing this matter, and that's where that matter is right

23 now.24 THE COURT: Okay.25 MR. BODNAR: And that proceeding, as I understand it,


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1 is still not totally concluded.2 THE COURT: Well, let me ask the question this way.3 MR. BODNAR: Yes.

4 THE COURT: As far as you're concerned, are you5 representing the Frazers?6 MR. BODNAR: I have an engagement letter that's signed7 by them that states that I represent them and that I would take8 whatever action is necessary in the bankruptcy court in9 Washington to establish that representation, whether it10 required going back, which I don't think it does at this point,11 since the trustee has essentially abandoned the right to12 proceed with this litigation and has advised Mr. Frazer that it13 can go forward. And the trustee in that matter has made a14 request to be -- I forget the exact language on the docket text15 entry, but to be relieved of his discharge of his obligations16 as trustee.

17 Mr. Frazer could tell you about the other litigation18 that's ongoing there. I don't know all the specifics about19 that litigation, but that's proceeding separately and I don't20 represent them with respect to that litigation.21 THE COURT: Okay.22 MR. BODNAR: But as I understand it, it's an adversary

23 proceeding that's related to that bankruptcy case in24 Washington.25 THE COURT: Mr. Bodnar, I'm trying unsuccessfully to


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1 get you to tell me yes or no. Are you in or are you not in?2 I don't -- because I want to either talk to you or to the3 Frazers. I don't want to talk to both of you.

4 MR. BODNAR: Understood.5 THE COURT: Okay.6 MR. BODNAR: At this point in time, Your Honor, the7 Liquidating Trustee's counsel has basically told me they don't8 recognize me as counsel for the Frazers because I presented9 them with the evidence of the docket text with respect to the10 request of the chapter trustee in that action to be discharged11 of his duties as trustee. And I've advised them with respect12 to what I've been advised by the Frazers as to the trustee's13 disinclination to become involved in this matter here in this14 court.15 THE COURT: Okay. Refresh me, is this -- this is a16 Chapter 7, I take it?

17 MR. BODNAR: Correct.18 THE COURT: Okay.19 MR. INDELICATO: Your Honor, if I may, this is Mark20 Indelicato on behalf of the Liquidating Trust. And again, as21 Mr. Carickhoff indicated, I apologize for not being in the22 court.

23 Mr. Bodnar is giving the Trust newfound powers. It is24 not in my place to recognize or not recognize his25 representation of Mr. Frazer. My question to him was simply


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1 that given there's a Chapter 7 case proceeding, do they need2 authorization from the bankruptcy court in Mr. Frazer's3 bankruptcy proceeding to represent him.

4 If he's representing to this Court that he does not5 believe he needs an order of the bankruptcy court, I'm happy to6 have him proceed on behalf of Mr. Frazer. Our concern was only7 that the Chapter 7 trustee be informed of the pendency of this8 action, that there be some acknowledgement by the Court in the9 Chapter 7 proceeding that they understood that this proceeding10 was pending in another bankruptcy court, that in theory if they11 were successful there might be some recovery, and that all12 parties were acknowledging that if in fact there is a recovery13 that it's not bound by the Chapter 7 estate.14 Absent, you know, an order of the Chapter 7 bankruptcy15 court, I was just concerned that I might get -- or the Trust16 may get blind sighted by a Chapter 7 trustee later on saying we

17 had no authority to negotiate either with Mr. Frazer or with18 Mr. Bodnar.19 THE COURT: Well, look, it's a Chapter 7 so either one20 or two things. Assuming there's a claim that's property of the21 Chapter 7 estate, it gets abandoned one of two ways. One,22 somebody files a motion and it gets abandoned or two, once the

23 case is over it's abandoned by operation of law.24 So I don't know -- I haven't seen the docket entry but25 I'm assuming what Mr. Bodnar is describing is an indication by


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1 the trustee that he's abandoned this asset. But I haven't seen2 it and I don't know. But I'll put it this way, as far as the3 Court's concerned, until someone brings the issue before it,

4 there's a claimant here represented by counsel.5 So Mr. Bodnar, let's address the substance of the6 matter. Mr. Schnitzer indicates we're looking for a trial date7 for the Frazers and the Cromwells. Is that so or is that not8 so? Is there other pre-trial activity to occur?9 MR. BODNAR: Your Honor, with respect to both those10 matters, there is additional discovery, I think, that needs to11 be taken, and we're in the process of reviewing that and I12 intend to address that with the Liquidating Trustee's counsel.13 And that's where that matter is. So I think in terms of14 setting a trial date the answer is yes, we could set a trial15 date so long as it was provided for enough time to --16 THE COURT: Is there a scheduling order in place in

17 either of these adversaries?18 MR. BODNAR: I don't believe there's a scheduling19 order with respect to the Frazers. There is a scheduling order20 with respect to Ms. Cromwell. And as you might recall, either21 at the last hearing, omnibus hearing, or the hearing before22 that I did request that a trial date be set in a month or two

23 with respect to Cromwell and there was no date set at that24 point in time.25 THE COURT: All right. Have the parties considered,


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1 in either of these adversaries, mediation?2 MR. BODNAR: I don't believe that I have specifically3 discussed mediation with the Frazers because of the pendency of

4 the bankruptcy case in Washington. But with respect to the5 Cromwells, to Ms. Cromwell, I have had that conversation and at6 that point we had decided not to proceed forward with7 mediation. So --8 THE COURT: Well, I'm going to order it in each of9 those cases. So what I'd like you to do, Mr. Bodnar, is10 consult with the Liquidating Trustee in Frazer and in Cromwell,11 come up with a scheduling order in Frazer. To the extent that12 there is a dispute about what other pre-trial activity should13 occur other than mediation, get back to me by conference14 telephone. With respect to Cromwell, again, consult with the15 Liquidating Trustee, pick a mediation date, and submit an16 order. And then when each mediation has been completed, advise

17 the Court. And each order should say the Court should be18 advised of the result, at which point if a trial date's19 necessary in either or both, simply ask for it and I'll fix20 them.21 MR. BODNAR: Yes, Your Honor. Thank you.22 THE COURT: Any questions about that?

23 MR. SCHNITZER: Your Honor, this is Edward Schnitzer24 from Hahn & Hessen. I just wanted to inform the Court, I25 apologize I wasn't able to interrupt before, there is a


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1 scheduling order in both Cromwell and Frazer. In fact the2 scheduling orders are, if not completely identical are3 virtually identical.

4 You entered both of the orders in November of 2010.5 And I would particularly note they both provided for discovery6 time periods; those have long since past and were completed,7 both Frazer and Cromwell. We responded to discovery, served8 discovery. So I would suggest -- and while I understand there9 is no, I guess, actual dispute before you right now, just so10 that at least the record's clear from the Trust's perspective,11 discovery in both of these matters is done, it was done12 pursuant to a scheduling order and it's been long done. I13 understand perhaps Mr. Bodnar is now involved and thinks14 otherwise, but I would suggest differently and I think the15 scheduling order at least confirms that with respect to the16 dates.

17 THE COURT: Well, I figured we'd outstrip them if18 there were scheduling orders. To the extent that there's a19 dispute about whether there should be further discovery, I'm20 assuming the appropriate party will raise that with the Court,21 but again, I'm ordering each to mediation.22 MR. INDELICATO: And Your Honor -- this is Mark

23 Indelicato. Just for clarification, there is still sub judice.24 Our objections related to the timeliness of the claims.25 THE COURT: Understood.


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1 MR. INDELICATO: Okay. Thank you, Your Honor.2 THE COURT: All right. Are we ready to move on to3 Carr?

4 MR. BODNAR: Thank you, Your Honor.5 MR. INDELICATO: From the Trust's perspective we are,6 Your Honor.7 THE COURT: All right. Ms. Carr, this is your motion.8 Are you on the phone?9 MS. CARR: Yes, Your Honor. This is Anita Carr for10 the record.11 THE COURT: All right. It's your time to be heard.12 MS. CARR: Yes, Your Honor. One quick question. Will13 I be allowed to have a little bit of rebuttal time after the14 Trust presents --15 THE COURT: Yes, briefly.16 MS. CARR: -- their oral argument?

17 THE COURT: Yes, briefly.18 MS. CARR: Yes, Your Honor, thank you. I will get19 started now.20 THE COURT: Okay.21 MS. CARR: On July 14th of 2010, Jamie Dimon, the CEO22 of Chase, said on a conference call: "There have been so many

23 flaws in mortgages that it's been an unmitigated disaster. We24 just really need to clean it up for the sake of everybody. And25 everybody is going to sue everybody else and it's going to go


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1 on for a long time."2 Well, in just one mortgage loan pool deal worth nearly3 a billion dollars, New Century sold 4,200 mortgage loans to

4 Chase. My mortgage loan may or may not have been one of them.5 These loans were securitized into this JPMAC2006-NC1 trust.6 All the loans in this securities offering were originated by7 Home123 or New Century. These types of deals were made8 repeatedly and with a feverish rate.9 Now the institutional investors who bought this10 security are suing Chase. This particular loan pool has had a11 default rate of over thirty-five percent. The Missal report12 commissioned by this Court and the investor lawsuits against13 New Century provide a plethora of wrongdoing by New Century.14 The Federal Grand Jury has yet to complete its investigation15 into New Century.16 THE COURT: Excuse me, Ms. Carr, may I ask you to

17 pause for a moment?18 MS. CARR: Yes, Your Honor.19 THE COURT: You're breaking up a little bit as you go20 along. What kind of phone connection are you on?21 MS. CARR: I'm on my home speaker. Maybe if I took it22 off speaker that would help.

23 THE COURT: I think that would be better. I don't24 want to miss anything.25 MS. CARR: Okay, Your Honor. Can you hear me now?


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1 THE COURT: Yes. That's much better. Thank you.2 MS. CARR: Okay. I'm sorry, Your Honor.3 Like tens of thousands of others, I'm a victim of

4 predatory lending and fraud by Home123 and New Century5 Mortgage. From the badgering calls from a Home123 sales rep,6 who insisted my prior loan was no good and we could do better,7 to the fraudulent loan documents which did not disclose to me8 who the true lender really was today, when I believe this venue9 is continuing to perpetrate the fraud and fraudulent10 concealment in this court. The failure to properly disclose11 the parties and terms and the outright lying that went on at12 the loan closing tolls my TILA rights.13 The fact that a notary who came to my home to have me14 sign the closing papers and then took every single piece of15 paper with her is further proof of the fraudulent acts by16 Home123. Even the TILA rescission notice, the three-day notice

17 was taken from me. I was told the documents would be mailed to18 me. Well, they weren't. And I had to hound this company to19 give me a copy, which they finally did some three months later.20 The fraud started at the inception of my refinance and21 now continues. In 2006 it was not apparent to me that Home12322 was actually acting as a loan broker when it was not licensed

23 in California to be a broker. Home123 never used any of its24 own funds to fund my loan, even though on the loan docs it25 claims to be the lender.


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1 On a more personal level, my own discovery, not court2 ordered, has now proved that the settlement was orchestrated by3 fraudulent concealment and I have not been able to demonstrate

4 this fraudulent concealment to this court. I've been denied5 discovery rights and production of evidence to prove the6 concealment. This involves not only fraud as to my mortgage7 but likely to thousands or tens of thousands of other8 mortgages.9 I'm going on to the new evidence. The Trust claimed10 in its opposition to my Motion for Reconsideration that I11 offered no new evidence. I'm entering documentary evidence in12 the form of an affidavit by Andres Rojas, the employee notary13 of Home123 and New Century.14 The Trust had also argued in the evidentiary hearing15 that all the issues regarding the notary and the signature of16 Andres Rojas was known to me prior to settlement. That is

17 indeed not the case. I testified in the evidentiary hearing18 that an e-mail that I sent to Mr. Indelicato regarding19 something I discovered at the Secretary of State, I testified20 that that was a dead end.21 My e-mail about that notary, prior to the settlement,22 was about the notary bond with the Secretary of State and she

23 has sent it to me, not the notary journal and not anything to24 do with Mr. Nagy's signature. The Secretary of State does not25 keep any notary journals. It's published on the California Web


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1 site for the Secretary of State that if any notary journals are2 sent to her she returns them immediately.3 All of the discussions with the Trust prior to

4 settlement were about the authenticity of the signature of5 Steve Nagy and not about the notary journal. I never had any6 communication with the notary prior to the settlement nor knew7 the whereabouts of the notary journal. He contacted me just8 prior to Thanksgiving, November of 2010, after I had sent out a9 blanket letter.10 Since the e-mails between myself and the notary were11 not allowed into evidence at the evidentiary hearing, I asked12 the notary to do the affidavit. He references in his affidavit13 that he sent me the pages of his notary journal attached to an14 e-mail that I've previously tried to enter as evidence at the15 evidentiary hearing.16 This affidavit also states that there was no

17 handwritten backdating on the document on the assignment when18 he notarized it. I ask the Court if Home123 sold my loan to19 Chase in February of 2006, as the Trust claims, then how is it20 that Home123 knew Carr was allegedly in default, and then21 Home123 put on the assignment in handwriting, "Effective22 4/12/2007", the backdating. Home123 would have had to have

23 first-hand knowledge of my payment history and whether or not I24 actually was in default.25 I'm now moving on to the issue of the fraudulent


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1 inducement by the Trust to settle. In that memorandum issued2 by the Court it states: "There's no credible evidence of any3 misrepresentation by the trustee in the record." That's the

4 memorandum at 8. "However, Ms. Carr gave testimony as to what5 was told to her by Mr. Indelicato and Mr. Rigano, and that was6 that the signature of Mr. Nagy was his and the assignment was7 valid. Now Carr provides Exhibit D in her Response and8 Objection" -- which is the D.I. 84 in my adversary9 proceeding -- "a letter from Mr. Indelicato dated August 17 of10 2010, just prior to the settlement. In paragraph 3, the second11 sentence states, 'First, based on our review of the document,12 it does not appear that Mr. Nagy's signature is forged.' Now,13 Carr relied on this to feel confident that the assignment,14 which is Exhibit B in Carr's Response and Objection, D.I. 84,15 was valid and legal."16 Again, this letter details the concern of the

17 authenticity of the Steve Nagy signature and does not mention18 the notary journal issue. It's not logical to believe I knew19 the notary journal issue when the Trust had just answered the20 question in my informal discovery that Andres Rojas was an21 employee of New Century and that the Trust did not have the22 notary journal.

23 The informal discovery responses came just prior to24 the settlement and one set actually came shortly after the25 settlement was done. In the same letter from Mr. Indelicato in


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1 the second paragraph in the fourth sentence is this statement:2 "It was Chase's obligation, not Home123, to record, if so3 desired, the assignment of your loan from New Century to

4 Chase." Yet the actual assignment doesn't go from Home123 to5 Chase; it goes from Home 123 to U.S. Bank. There's not a6 mention of Chase. This is Exhibit B in the Carr Response and7 Objection, D.I. 84.8 Additionally, under California Government Code 27361.69 for recorded documents it states that the upper left corner of10 the recorded document is for: "a) The return address to whom11 recorded document is to be returned to and b) The name of the12 person requesting the recording." If you look at the corporate13 deed of assignment, in both of those instances the document14 says that it is Home123 in Irvine, California that the recorded15 document is to be returned to after recording. And the name of16 the person requesting the recording is indeed Home123 in

17 Irvine, California. This was done after the New Century18 bankruptcy was declared on 4/2 of '07.19 In the case of the corporate assignment of deed for20 Carr's property, it was Home123 in both instances. And Home12321 never sent Carr a copy of this document. This is indicative of22 further cover up of the scheme to defraud. The Trust insists

23 that Chase was the new servicer when the assignment goes to24 U.S. Bank. Again, Exhibit B, D.I. 84.25 Also under California Government Code, Section


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1 27201(b), 27280.5, and the Civil Codes 1213 and 1218, all2 signatures must be original on the recorded documents. This3 does not mean a squiggle or one initial; this means a full

4 signature.5 This also begs the question posed by Carr, if as Mr.6 Indelicato's letter claims, Home123 sold my loan to JPMorgan7 Chase on February 24th of '06 and in May 2006 the servicing was8 transferred to Chase, why is the assignment being executed and9 recorded by Home123 over fourteen months later? It is Home12310 that is requesting the recorded document be sent back to it.11 A more concerning issue is if Carr's loan was12 allegedly sold to Chase in February of '06 and it went into a13 mortgage pool which was securitized as JPMAC2006-NC1, and the14 closing date in the PSA states April of 2006 for that15 securities trust is the cutoff date, then Carr's loan never16 made it into that trust since the assignment says both the note

17 and deed and it is executed; the Carr assignment is executed in18 May of 2007. This points to a tax evasion scheme in violation19 of IRS REMIC laws and New York trust laws.20 Another violation of IRS REMIC law is that a mortgage21 cannot be assigned to a securities trust if it is in default.22 Since Carr received a notice of default, whether or not her

23 loan was actually in default, and the notice of default was24 dated April 12th of 2007, then how could Carr's loan be put25 into a REMIC securities trust by way of executing that


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1 assignment?2 Additionally, on page 2 of the letter from Mr.3 Indelicato, the very first sentence is: "In light of the above

4 facts, the trustee does not believe you have a claim against5 the estate", followed by an offer to settle for 35,000 dollars.6 Then in a letter dated August 11, 2010 from Mr. Indelicato,7 which is Exhibit E, D.I. 84 in my adversary proceeding, the8 settlement offer is for 25,000. In this letter the Trust is9 trying to convince Carr that hers is an unsecured claims worth10 only pennies on the dollar. And the Trust goes into elaborate11 calculations.12 Mr. Indelicato goes on in great detail how the Trust13 has no control over my loan which was secured by my residence.14 Yet there's been no proof at all that my loan or deed was15 validly and legally transferred anywhere. It is now clear that16 this type of misinformation is based on hearsay by the Trust.

17 The Trust intentionally and wrongfully misled Carr into an18 unfair settlement. The settlement was based on fraud and19 amounted to nothing more than a bribe. The settlement should20 be set aside.21 Now regarding the issue of paying back the 60,00022 dollars from the settlement. In my testimony at the

23 evidentiary hearing, I stated I would be willing to execute a24 note, which is a negotiable instrument, for 60,000, if25 required, to pay back the settlement. However, under


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1 California Civil Code 1693, if restoration of the consideration2 is impossible because the settlement money has been spent, the3 financially constrained parties can delay restoration until

4 judgment unless the defendants can show substantial prejudice.5 Carr's offer to provide a note of 60,000 to New Century6 Liquidating Trust was fair and reasonable.7 The Trust has provided hearsay and no evidence at all8 that Carr's loan was transferred anywhere, not even to Chase in9 February of 2006 as the Trust claims.10 Since Carr introduced the suspicious assignment as11 early November 23rd of 2009, adversary proceeding docket entry12 8, the Trust had ample time to prove to Carr and the Court that13 it was indeed signed validly by Steve Nagy and that the New14 Century Liquidating Trust employee notary Andres Rojas executed15 his job as a notary in a proper and legal manner.16 The only explanation for this reliance on hearsay and

17 to negligently ignore providing proof is to continue to18 fraudulently conceal assets from this bankruptcy. Quite19 possibly they're concealed in entities not listed in this20 bankruptcy case. This is bankruptcy fraud.21 Carr reasserts her belief that assets are being22 concealed from this Court. Carr reasserts that the collection

23 rights to her loan were disposed of just prior to or around the24 bankruptcy filing improperly. Carr still does not know where25 any collection rights are or if they even existed. The Trust


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1 continues to insist that the Carr loan was properly transferred2 prior to the petition date assigned in their Objection to the3 Carr Motion for Reconsideration and number -- in line 21.

4 Yet this flies in the face of the assignment executed by5 Home123 in May of 2007, a fraudulent transfer no less. Carr6 believes that her loan never left New Century.7 Now regarding the 2008 global orders for relief from8 stay. As early as June 30th of 2009 Carr filed a motion for9 relief from stay to proceed with California Superior Court case10 and her motion to compel discovery, docket entry 9704 in the11 main case of NCLT.12 This was prior to filing even a proof of claim or the13 adversary proceeding in this matter. Carr at that time was not14 told about the 2008 global orders for relief from stay by the15 Trust nor the Court. At that point in time in 2009, the16 amended 2008 global relief from stay order terminated the

17 automatic stay under Section 362(a) of the Bankruptcy Code to18 permit the commencement or continuation of any act to exercise19 any rights and remedies against real property under20 nonbankruptcy law. Carr has been prejudiced by this Court as21 this Court and the Trust knew of Carr's California case and22 that both Home123 and New Century were listed as defendants in

23 that case which was filed in March of 2009. Elizabeth Sloan of24 Blank Rome filed a notice of stay of proceedings, a response,25 on April 18th, 2009 in Carr's California case. This is Exhibit


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1 F of Carr's Response and Objection which is docket entry 84 of2 the AP.3 Carr's California case has been damaged by this

4 prejudice. By not affording Carr the benefit of the 20085 global relief from stay this Court has caused unnecessary6 litigation and delay. Carr's due process rights have been7 violated.8 This Court had to issue an emergency injunction,9 supposedly to clarify the 2008 global relief from stay order on10 May 25th of 2011 after Carr testified in the evidentiary11 hearing in April of 2011 that her California case was damaged.12 Now I would just like to discuss the Bodnar issue.13 Carr directs the Court's attention to Exhibit G of14 docket entry 84, Carr's Response and Objection, which is an ECF15 filing, a court filing, a PACER filing transaction started by16 Alan Root who is opposing counsel in this matter. On the

17 second page, the third entry from the bottom of this exhibit it18 states, "Joseph J. Bodnar, on behalf of Plaintiff Alan M.19 Jacobs, as liquidating trustee of the New Century Liquidating20 Trust", and it has Mr. Bodnar's e-mail address. Mr. Bodnar has21 also called another former pro se in this matter and told him22 that he did do some work for this bankruptcy trustee. Carr

23 maintains that Mr. Bodnar is a mole for the bankruptcy trustee24 in this matter. Carr respectfully requests that the counsel25 for the Trust be sanctioned for lying to the Court about Bodnar


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1 and their assertions that he never worked for the Trust. See2 number 37, line 37 of the Trust's Objection to Carr's Motion3 for Reconsideration.

4 As I have stated many times before, California is a5 nonjudicial foreclosure state based on a process, a paper6 process of valid recorded documents in the appropriate county.7 Typically after a loan closing a deed is recorded, next any8 assignments, next any substitution of the trustee. If there is9 a legitimate default then a notice of default is recorded.10 Next a notice of trustee sale is recorded. Then a trustee's11 deed upon sale is recorded. These recordings must be in the12 proper sequence and must be valid and legal, not forged or13 fraudulent. The assignments must go from A to B to C to D.14 There must be a clear chain of title.15 My conclusion is Carr has demonstrated new evidence16 and the need to correct clear and manifest injustice. These

17 are two of the prongs out of three in order to allow a Motion18 for Reconsideration under either the Bankruptcy Code or the19 Federal Rules of Bankruptcy Procedures.20 Carr has more than proved that prior to settlement the21 issue on the table was the validity of the Steve Nagy signature22 and not any issues with the notary journal. Carr has testified

23 under oath at the evidentiary hearing that she would execute a24 note, which is a negotiable instrument, in the amount of 60,00025 to pay back the Trust for the settlement monies. Carr


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1 maintains the settlement was a bribe and was based on fraud.2 Carr maintains that her loan never validly was transferred to3 any entity and remains with this bankruptcy estate and possibly

4 it is concealed from this Court.5 Carr has been injured and damaged by the fraudulent6 actions of the defendant debtor employees or former employees.7 Carr respectfully requests that a quiet title be immediately8 executed, Exhibit C of the Carr Response and Objection, which9 is docket entry 84 in her AP, that her credit report be cleared10 and for a monetary award, or in the alternative, the adversary11 proceeding to be reopened. Carr also respectfully requests12 that her -- the -- sorry -- that the -- if I just may have a13 moment, Your Honor?14 THE COURT: Yes. That's fine.15 MS. CARR: -- that her request for -- oh, shoot. I'm16 sorry, Your Honor. I'm finished.

17 THE COURT: All right. I'll give you a minute, Ms.18 Carr, if you'd like.19 MS. CARR: My fibromyalgia just kicked in and I have20 a -- I have just a brain thought wash.21 THE COURT: All right. Thank you.22 I'll hear from the liquidating trustee.

23 MR. INDELICATO: Thank you, Your Honor. I'm going to24 try to be brief, given that I'm not in the courtroom, and I25 think our papers outline very concisely our Objection to the


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1 Motion for Reconsideration.2 I would like to start, though, Your Honor, and remind3 the Court that this is a Motion for Reconsideration. It is not

4 the time to argue the merits of Ms. Carr's underlying claims.5 As this Court has found in the May 10, 2011 decision, those6 issues were all resolved pursuant to the terms of the7 settlement agreement entered into between the Trust and Ms.8 Carr. And in fact, the terms of the settlement, including the9 relief therein, are binding on the parties.10 It's interesting to note that Ms. Carr at some point11 indicates that she knew of issues or disclosed them to the12 Trust and the Court in 2009, yet she indicates that they are13 new evidence now and were not known to her when the settlement14 was executed in 2010.15 As this Court is aware and as was set forth in our16 pleadings, motions for reconsideration are to be strictly

17 construed, they're governed by Rule 59(e) of the Federal Rules.18 And there are three categories of issues that can be addressed19 in a Motion for Reconsideration: an intervening change in the20 controlling law, the availability of new evidence, and the need21 to correct clear and manifest injustice.22 And there's no argument that there's an intervening

23 change in controlling law. Ms. Carr has focused her arguments24 on (b) and (c), the availability of new evidence and the need25 to correct clear and manifest injustice.


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1 Your Honor, with respect to the new evidence, I would2 submit that Ms. Carr is now beginning or trying to split hairs3 in indicating in that all of the correspondence and e-mails in

4 which we were discussing both the notary and the Steve Nagy's5 signature that really then she was only discussing the bond and6 not the journals, which as we've set forth in prior pleadings,7 Your Honor, we believe is irrelevant.8 But suffice it to say, we believe that the issue of9 the notary, as we demonstrated at the evidentiary hearing, was10 fully known to Ms. Carr prior to entry into the settlement11 agreement and we do not believe there's any new evidence. And12 clearly, those were issues that were discussed at the13 evidentiary hearing. They're not issues that came to light14 after the evidentiary hearing.15 With respect to correct and clear manifest injustice,16 Your Honor, this is the one, and I apologize for getting a

17 little indignant, but, you know, I do take my reputation18 seriously. I take the Court's reputation, I take Mr. Bodnar's19 reputation; we are officers of the court and this is a court of20 law. I do not appreciate people making accusations about the21 veracity, the integrity of the process of the people in order22 to make their point.

23 I'm not going to address the merits of them except to24 address issues with respect to Mr. Bodnar. He's in court. He25 can speak for himself. Mr. Bodnar was never retained or


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1 employed by the Trust. He is not a mole of the Trust. We had2 no communications with him regarding Ms. Carr, subsequent or3 prior to his meeting, other than Mr. Bodnar may have called

4 indicating did he think he would be helpful in the New Century5 process if he were to represent some of the individual pro se6 plaintiffs. And the only comment we would have made was, to7 the extent people are represented by counsel it might help8 expedite the process. But he is not a mole. We have had no9 communications. The Trust has not benefited one iota from his10 conversations with Ms. Carr or any of the other pro se11 defendants.12 Your Honor, I think the record is clear, as evidenced13 by the Court's ruling in May of this year. Ms. Carr knowingly14 and voluntarily entered into a settlement agreement in which15 she received compensation from the Trust in settlement of all16 her claims.

17 She indicates that the Trust misled her by indicating18 that she would receive pennies on the dollar. Your Honor,19 bankruptcy as a matter -- the Court can take judicial notice20 that unsecured claims in bankruptcy cases receive a21 distribution based on what is in the estate. In this case,22 unfortunately, the claims far exceed the assets that have been

23 liquidated and made available for distribution. The Trust has24 made two interim distributions to creditors, and depending on25 which class you are in, the distributions have been anywhere


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1 from four to I believe twelve cents on the dollar. So clearly,2 as an unsecured creditor, Ms. Carr would have received pennies3 on the dollar. There's no manifest error in that. There's no

4 misleading. There's no fraud. It is a fact of the bankruptcy5 process and it is a fact of this case.6 Your Honor, we are again put in the position of being7 accused of misleading and lying with respect to the 2008 global8 relief stay order. When that was raised by Ms. Marks we felt9 compelled to bring a motion to the Court. That motion was10 heard and an order entered. We attached a copy of that order11 to our Response to Ms. Carr's Motion for Reconsideration. And12 the order very simply says, as it relates to the global relief13 stay order, the order was not intended to permit third parties14 to sue the debtor's estate and seek compensation. The order15 was permitted -- was entered into to stop a flurry of cases,16 sometimes dozens if not hundreds, in which parties were seeking

17 relief from the stay either to commence and continue18 foreclosure actions on properties in which the debtor had19 nominal title but had no economic interest in the loan. It was20 merely permitted to clear title and proceed with foreclosures,21 not to seek monetary damages against the estate. So the global22 relief stay order did not at all affect adversely Ms. Carr's

23 California action. She commenced a relief stay motion, the24 Trust objected to it, and it was properly denied by the Court.25 There is no manifest injustice to Ms. Carr.


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1 Your Honor, I believe what Ms. Carr has attempted to2 do is reargue yet again a lot of the issues she has argued3 previously. I believe with a lot of red herrings, name calling

4 innuendo she is trying to establish facts that can fit into the5 Motion for Reconsideration. I do not believe those facts6 exist.7 I believe that the trustee in its Objection has made8 clear and concise arguments as to why the Motion for9 Reconsideration should not be granted. I do not believe there10 is any new evidence. I do not believe the issues related to11 Andres Rojas and the notary journal are new evidence. I think12 if the Court will look at the evidence in the initial hearing,13 there was memos in which Mr. Rojas was mentioned in the context14 of the settlement discussions, and in fact in part of the last15 negotiations in an e-mail, and I think it was Exhibit 1 of Ms.16 Carr's submissions in the adversary proceeding, it was an

17 e-mail on October 3, 2010 where she specifically references the18 California state regarding notary Andres Rojas. She knew of19 the issues. She knew of them when she settled. She signed it20 voluntarily and with knowledge of its terms. She executed it,21 she was paid, she accepted the compensation. The adversary22 proceeding is dismissed. Your Honor, I believe the Motion for

23 Reconsideration, in its entirety, should be denied.24 Thank you.25 THE COURT: Thank you.


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1 Ms. Carr, briefly?2 MS. CARR: Your Honor?3 THE COURT: Yes, you may proceed.

4 MS. CARR: Yes, Your Honor, Anita Carr.5 I disagree completely with Mr. Indelicato. I have6 entered as Exhibit A and docket entry 84 in my Response and7 Objection to the Trust the actual affidavit, which is new8 evidence. This affidavit, by the notary Andres Rojas, was9 signed the 4th day of June of 2011. And it itself was10 notarized by another notary in Orange County. This is the new11 evidence. It's clear on its face that it's new evidence.12 Carr had no knowledge at all of this issue with the13 notary journal prior to locating the notary. And as I've14 stated many times before, the notary called me the week before15 Thanksgiving of 2010. That was my first contact with the16 notary. This was after the settlement. The notary journal

17 issue was never known by me until after the settlement. And in18 fact, I mentioned today in my testimony, in my oral argument,19 that the issue with the notary where I contacted the Secretary20 of State was in reference to the notary bond which is a one-21 page document. It is not the notary journal issue. And I feel22 I've more than proven why the Motion for Reconsideration should

23 go forth.24 THE COURT: All right.25 MS. CARR: I'm not --


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1 THE COURT: Thank you.2 MS. CARR: I'm -- thank you, Your Honor.3 THE COURT: All right. I didn't mean to cut you off,

4 Ms. Carr. I thought you might be done. Are you finished?5 MS. CARR: Yes, I am finished. Thank you.6 THE COURT: All right. Thank you. Okay. I will7 issue a decision on the Motion for Reconsideration in due8 course.9 Mr. Carickhoff, is there anything further for today?10 MR. CARICKHOFF: I have nothing further, Your Honor.11 THE COURT: All right. Thank you. That concludes12 this hearing. The court will stand in recess.13 MR. CARICKHOFF: Thank you.14 (Whereupon these proceedings were concluded at 12:00 PM)1516

171819202122

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36

12 C E R T I F I C A T I O N3

4 I, Sharona Shapiro, certify that the foregoing transcript is a5 true and accurate record of the proceedings.6789

10 ______________________________________11 SHARONA SHAPIRO12 AAERT Certified Electronic Transcriber CET**D 4921314 eScribers, LLC15 P.O. Box 753316 New York, NY 10116

1718 Date: August 1, 201119202122

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New Century TRS Holdings, Inc.07-10416-KJC July 26, 2

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(3) copy - execu


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exercise (1)25:18

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25:25;26:13,17;28:8;

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existed (1)24:25

expedite (1)31:8

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Federal (3)16:14;27:19;29:17

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followed (1)23:5

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foreclosures (1)32:20

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Home123 (22)16:7;17:4,5,16,21,23;

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indicative (1)21:21

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instrument (2)23:24;27:24

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intend (1)12:12

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(4) executing - intend


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32:13

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interest (3)8:13,21;32:19

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interim (1)31:24

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IRS (2)22:19,20

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(5) intentionally - Na


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proof (4)17:15;23:14;24:17

25:12

proper (2)24:15;27:12

properly (3)17:10;25:1;32:24

properties (1)



(6) Nagy's - proper


43/45


32:18

property (3)11:20;21:20;25:19

prove (2)18:5;24:12

proved (2)18:2;27:20

proven (1)34:22

provide (2)16:13;24:5

provided (4)8:8;12:15;14:5;24:7

provides (1)20:7

providing (1)24:17

PSA (1)22:14

published (1)18:25

pursuant (2)14:12;29:6

pursuing (2)8:14,22

put (5)8:14;12:2;19:21;

22:24;32:6

Q

quick (1)15:12

quickly (1)5:13

quiet (1)28:7

Quite (1)24:18

R

raise (1)14:20

raised (2)7:18;32:8

RALPH (1)4:10

rate (2)16:8,11

rather (1)

5:9reached (1)

6:6

ready (1)15:2

real (1)25:19

really (4)7:9;15:24;17:8;30:5

reargue (1)33:2

reason (2)

6:3,13

reasonable (1)24:6

reasserts (2)24:21,22

rebuttal (1)15:13

recall (3)6:23;7:2;12:20

receive (2)31:18,20

received (3)22:22;31:15;32:2

recently (1)6:2

recess (1)35:12

recognize (3)10:8,24,24

Reconsideration (15)5:19;18:10;25:3;27:3,

18;29:1,3,16,19;32:11;

33:5,9,23;34:22;35:7

record (7)7:14;8:6,14;15:10;

20:3;21:2;31:12

recorded (12)21:9,10,11,14;22:2,9,

10;27:6,7,9,10,11

recording (3)21:12,15,16

recordings (1)27:11

record's (1)14:10

recovery (2)11:11,12

red (1)33:3

reference (1)34:20

references (2)19:12;33:17

referred (1)8:15

refinance (1)17:20

Refresh (1)10:15

regarding (6)18:15,18;23:21;25:7;

31:2;33:18regularly (1)

6:23

related (3)9:23;14:24;33:10

relates (1)32:12

reliance (1)24:16

relied (1)20:13

relief (12)

25:7,9,14,16;26:5,9;

29:9;32:8,12,17,22,23

relieved (1)9:15

remains (1)28:3

remedies (1)25:19

REMIC (3)

22:19,20,25remind (1)

29:2

reopened (1)28:11

rep (1)17:5

repeatedly (1)16:8

report (2)16:11;28:9

represent (6)8:3,4;9:7,20;11:3;31:5

representation (4)

7:17,19;9:9;10:25represented (2)

12:4;31:7

representing (2)9:5;11:4

reputation (3)30:17,18,19

request (6)6:3;7:4;9:14;10:10;

12:22;28:15

requested (2)5:23;6:10

requesting (3)21:12,16;22:10

requests (3)26:24;28:7,11

required (2)9:10;23:25

rescission (1)17:16

residence (1)23:13

resolve (1)6:17

resolved (2)5:15;29:6

resolving (1)6:9

respect (22)6:21,25;7:3,4,15,18,

21;8:9;9:20;10:9,11;

12:9,19,20,23;13:4,14;

14:15;30:1,15,24;32:7

respectfully (3)26:24;28:7,11

responded (1)14:7

Response (9)20:7,14;21:6;25:24;

26:1,14;28:8;32:11;34:6

responses (1)20:23

restoration (2)24:1,3

result (1)13:18

retained (1)30:25

return (1)

21:10returned (2)

21:11,15

returns (1)19:2

review (1)20:11

reviewing (1)12:11

Rigano (1)20:5

right (14)7:12;8:22;9:11;12:25;

14:9;15:2,7,11;28:17,21;

34:24;35:3,6,11rights (6)

17:12;18:5;24:23,25;

25:19;26:6

Rojas (8)18:12,16;20:20;24:14;

33:11,13,18;34:8

Rome (2)5:5;25:24

Root (1)26:16

Rule (1)29:17

Rules (2)

27:19;29:17ruling (1)

31:13

run (1)5:13

S

sake (1)15:24

sale (2)27:10,11

sales (1)17:5

same (1)20:25

sanctioned (1)26:25

saying (1)11:16

schedule (1)5:9

scheduled (1)7:7

scheduling (9)12:16,18,19;13:11;

14:1,2,12,15,18

scheme (2)21:22;22:18

Schintzer (1)5:25

SCHNITZER (5)5:25;6:20;12:6;13:2

23

Se (6)

4:3,7,11;26:21;3110

second (3)20:10;21:1;26:17

Secretary (5)18:19,22,24;19:1;

34:19

Section (2)21:25;25:17

secured (1)23:13

securities (4)16:6;22:15,21,25

securitized (2)

16:5;22:13security (1)

16:10

seek (2)32:14,21

seeking (1)32:16

sent (7)18:18,23;19:2,8,1

21:21;22:10

sentence (3)20:11;21:1;23:3

separately (1)9:19

September (3)5:23;6:12,16

sequence (1)27:12

seriously (1)30:18

served (1)14:7

servicer (1)21:23

servicing (1)22:7

set (7)12:14,22,23;20:24

23:20;29:15;30:6setting (1)

12:14

settle (2)20:1;23:5

settled (1)33:19

settlement (27)18:2,16,21;19:4,6

20:10,24,25;23:8,18,

19,22,25;24:2;27:20,2

28:1;29:7,8,13;30:1



(7) property - settlem


44/45


31:14,15;33:14;34:16,17

shoot (1)28:15

shortly (1)20:24

shoulders (1)8:18

show (1)24:4

shrugged (1)8:18

sighted (1)11:16

sign (1)17:14

signature (9)18:15,24;19:4;20:6,

12,17;22:4;27:21;30:5

signatures (1)22:2

signed (4)9:6;24:13;33:19;34:9

simply (3)

10:25;13:19;32:12single (1)

17:14

site (1)19:1

Sloan (1)25:23

sold (4)16:3;19:18;22:6,12

somebody (1)11:22

someone (1)12:3

sometimes (1)

32:16sorry (3)

17:2;28:12,16

sort (1)8:18

speak (1)30:25

speaker (2)16:21,22

specifically (2)13:2;33:17

specifics (1)9:18

spent (1)

24:2split (1)

30:2

squiggle (1)22:3

stand (1)35:12

start (2)5:19;29:2

started (3)15:19;17:20;26:15

State (7)

18:19,22,24;19:1;

27:5;33:18;34:20

stated (3)23:23;27:4;34:14

statement (1)21:1

states (7)9:7;19:16;20:2,11;

21:9;22:14;26:18

status (8)5:17,22,23;6:22;7:2;

8:10,11,12

stay (13)25:8,9,14,16,17,24;

26:5,9;32:8,13,17,22,23

Steve (5)19:5;20:17;24:13;

27:21;30:4

still (3)9:1;14:23;24:24

stop (1)32:15

strictly (1)

29:16sub (1)

14:23

subject (2)5:15;8:17

submissions (1)33:16

submit (2)13:15;30:2

subsequent (1)31:2

substance (1)12:5

substantial (1)

24:4substitution (1)

27:8

successful (1)11:11

sue (2)15:25;32:14

suffice (1)30:8

sufficient (1)8:19

suggest (2)14:8,14

suing (1)

16:10Superior (1)

25:9

supposedly (1)26:9

suspicious (1)24:10

T

table (1)27:21

talk (2)10:2,3

tax (1)22:18

telephone (1)13:14

TELEPHONICALLY (1)

4:6

telling (1)

8:3tens (2)

17:3;18:7

terminated (1)25:16

terms (5)12:13;17:11;29:6,8;

33:20

testified (4)18:17,19;26:10;27:22

testimony (3)20:4;23:22;34:18

Thanksgiving (2)19:8;34:15

theory (1)11:10

therein (1)29:9

thereof (1)7:11

third (2)26:17;32:13

thirty-five (1)16:11

though (2)17:24;29:2

thought (2)28:20;35:4

thousands (3)17:3;18:7,7

three (3)17:19;27:17;29:18

three-day (1)17:16

TILA (2)17:12,16

timeliness (2)7:1;14:24

times (2)27:4;34:14

timing (1)7:9

title (4)27:14;28:7;32:19,20

today (5)6:21;7:3;17:8;34:18;

35:9

today's (1)6:11

told (5)10:7;17:17;20:5;

25:14;26:21

tolls (1)17:12

took (2)16:21;17:14

totally (1)9:1

train (1)5:9

trains (1)5:8

transaction (1)

26:15transfer (1)

25:5

transferred (5)22:8;23:15;24:8;25:1;

28:2

trial (6)7:8;12:6,14,14,22;

13:18

tried (2)5:7;19:14

true (1)17:8

Trust (48)

4:15;5:6;6:1;10:20,23;11:15;15:14;16:5;18:9,

14;19:3,19;20:1,19,21;

21:22;22:15,16,19,21,

25;23:8,10,12,16,17;

24:6,7,9,12,14,25;25:15,

21;26:20,25;27:1,25;

29:7,12;31:1,1,9,15,17,

23;32:24;34:7

Date post:	07-Apr-2018
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RED HERRINGS, MOLES & A FEISTY ORAL ARGUMENT BY HOMEOWNER-TRANSCRIPT

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