IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA+ BRIAN BLY+BRAIN KORTE+AMERIQUEST+DEUTSCHE BANK, NATIONAL TRUST COMPANY, AS TRUSTEE IN TRUST FOR THE BENEFIT OF THE CERTIFICATE HOLDERS FOR AMERIQUEST MORTGAGE 5 SECURITIES TRUST 2005-R8, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R8,+ CACE09024188(1)Posted: March 31, 2012
Bly read letterBryan Bly’s exhibit 1, 8-18-11
Deft exhibit 1, Bryan Bly, 8-18-11
Deft exhibit 2, Bryan Bly, 8-18-11
Deft exhibit 3, Bryan Bly, 8-18-11
Deft exhibit 4, Bryan Bly, 8-18-11
Deft exhibit 5, Bryan Bly, 8-18-11
Deft exhibit 6, Bryan Bly, 8-18-11
Bryan Bly, the most famous robo-signer at NTC, signed thousands of Assignments and Affidavits as “Vice-President, PNC Bank, as successor by merger National City Bank, successor by merger Harbor Federal Savings Bank.” On many documents, an Ohio address appears underneath Bly’s signature. Bly, however, was never a Vice President of PNC. This was just one of the many titles Bly used so that NTC could produce documents needed for foreclosures.”"”"
1 IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
3 DEUTSCHE BANK, NATIONAL TRUST
COMPANY, AS TRUSTEE IN TRUST FOR
4 THE BENEFIT OF THE CERTIFICATE
HOLDERS FOR AMERIQUEST MORTGAGE
5 SECURITIES TRUST 2005-R8, Case No.
ASSET-BACKED PASS-THROUGH CACE09024188(1)
6 CERTIFICATES, SERIES 2005-R8,
9 ZAIDY L. GANTT, et al.,
_ _ _ _ _ _ _ _ _ _ _ _ _ /
12 DEPOSITION OF: BRYAN BLY
13 DATE: August 18, 2011
14 TIME: 1:54 p.m. to 2:12 p.m.
15 PLACE: Korte & Wortman, P.A.
3001 Executive Drive, Suite 300
16 Clearwater, Florida
17 PURSUANT TO: Notice by counsel for
Defendants for purposes of
18 discovery, use at trial
or such other purposes
19 as are permitted under
the Florida Rules
20 of Civil Procedure
21 BEFORE: LISA A. SIMONS-CLARK, RPR, CRR
Notary Public, State of
22 Florida at Large
Pages 1 to 27
2 MEGHAN KENEFIC, ESQUIRE
Shapiro & Fishman, LLP
3 1004 North Dale Mabry Highway, Suite 112
Tampa, Florida 33618
4 (813) 880-8888
Attorney for Plaintiff
BRIAN K. KORTE, ESQUIRE
6 Korte & Wortman, P.A.
2041 Vista Parkway, Suite 102
7 West Palm Beach, Florida 33411
– and -
MICHAEL SINGER, ESQUIRE
10 Korte & Wortman, P.A.
3001 Executive Drive, Suite 300
11 Clearwater, Florida 33762
Attorneys for Defendants
RYAN CHRISTOPHER RODEMS, ESQUIRE
13 Barker, Rodems & Cook, P.A.
501 East Kennedy Boulevard, Suite 790
14 Tampa, Florida 33602
– and -
ADINA L. POLLAN, ESQUIRE (VIA TELEPHONE)
17 Akerman Senterfitt
50 North Laura Street, Suite 3100
18 Jacksonville, Florida 32202
19 Attorneys for Deponent
20 ALSO PRESENT:
21 Nicole Colson, paralegal
3 DIRECT EXAMINATION BY MR. KORTE 4
4 CERTIFICATE OF OATH 24
5 REPORTER’S CERTIFICATE 25
6 READ AND SIGN LETTER 26
7 ERRATA SHEET 27
9 DEFENDANTS’ EXHIBITS
10 ID’d MARKED
1 – Subpoena Duces Tecum 4 4
11 2 – Assignment of Mortgage 17 4
3 – Complaint 4
12 4 – Non-Party Witnesses Citi Residential
Lending, Inc., Nationwide Title Clearing,
13 and Bryan Bly’s Motion for Protective Order 4
5 – Limited Power of Attorney 13 13
14 6 – Unanimous Written Consent of the
Executive Committee of the Board of
15 Directors of Citi Residential Lending,
Inc. 12 13
17 BLY EXHIBITS
1 – Transcript of Judge Lazarus hearing on
18 Tuesday, June 7, 2011 23 23
1 (Defendants’ Exhibit Nos. 1, 2, 3, and 4 were
2 marked for identification.)
3 BRYAN BLY,
4 the witness herein, being first duly sworn on oath, was
5 examined and deposed as follows:
6 THE WITNESS: I do.
7 DIRECT EXAMINATION
8 BY MR. KORTE:
9 Q. Sir, will you state your name, spelling your
10 last for me, please?
11 A. Bryan Bly. It’s B-r-y-a-n, B-l-y.
12 Q. Mr. Bly, my name is Brian Korte. I’m going to
13 be taking your deposition today in the matter of
14 Deutsche Bank vs. Gantt. Did you receive a subpoena in
15 this case?
16 A. Yes.
17 Q. All right, sir. What I’m going to do is just
18 give you some ground rules to a deposition — I’m sure
19 you’ve had your deposition taken in the past — and
20 just let me know whether or not you understand my
21 instructions. Okay?
22 A. Okay.
23 Q. Just — if you don’t know the answer to a
24 question, tell me I don’t know. If you need more time,
25 just please tell me that you need more time to respond
1 to a question before I move on; and, if you give me a
2 response to a question, you’ll — that will be the –
3 well, if you give me a response, I’ll assume that you
4 understood my question.
5 A. Okay.
6 Q. Is that fair?
7 A. Fair.
8 Q. All right. Sir, will you give me the benefit
9 of your educational background, starting from the time
10 you left high school?
11 MR. RODEMS: No. We’re not going to do that.
12 That’s not relevant to the case, and we’re not
13 going to get into that.
14 MR. KORTE: What do you mean? You’re
15 instructing him not to answer about his education?
16 MR. RODEMS: Right.
17 BY MR. KORTE:
18 Q. All right. Give me the benefit of your work
19 history, starting from the time that you left high
21 MR. RODEMS: No. We’re not going to do that.
22 This man has been the subject of threats because
23 of the previous deposition that was posted. We’re
24 going to stick to relevant information.
25 MR. KORTE: The rules require as to attempt to
1 reach a resolution. I understand you filed a
2 protective order. The judge basically –
3 MR. RODEMS: He said take it on a
4 case-by-case, question-by-question basis.
5 MR. KORTE: Exactly. So you’re not going to
6 answer questions with education or his work
8 MR. RODEMS: No. It’s not relevant.
9 MR. KORTE: I believe it is. So you’re
10 instructing him not to answer my questions as to
11 education or work history?
12 MR. RODEMS: Correct.
13 BY MR. KORTE:
14 Q. All right, sir. Can you tell me where you
15 currently work?
16 A. Nationwide Title Clearing.
17 Q. How long have you worked for Nationwide Title
19 A. Over eight years.
20 Q. And what position were you hired with with
21 Nationwide Title Clearing?
22 A. I think it was called post scanning.
23 Q. What did you do in post scanning?
24 A. Prepared and re — reassembled documents that
25 were scanned and prepared them to go out.
1 Q. And what position did you have after you left
2 post scanning?
3 A. I went into processing.
4 Q. What does a processor do?
5 A. Preparing the docs. to meet the legal
6 requirements to be recorded.
7 Q. What do you mean prepare them for legal doc.?
8 A. Well, for example, maybe the County requires a
9 legal property description, so you’re attaching that;
10 or if it requires a cover sheet, like New York, the
11 boroughs, I prepare that.
12 Q. Are these documents that have already been
13 executed, or are these documents that are being
14 reassembled, or what kind of documents are these?
15 A. They’re documents being prepared to be
17 Q. Okay. And did you have another job after
19 A. Within processing I became into signing.
20 Q. What’s a signing job? I don’t understand what
21 it is.
22 A. Once you’re on the corporate resolution,
23 you’re authorized to sign on behalf of clients.
24 Q. Gotcha. So at some point in time while you
25 were a processor, you became also a signer?
1 A. Correct.
2 Q. So you did both. The big job was processor,
3 the little job was signer?
4 A. Right.
5 Q. Okay. Or was it the other way around? I
6 mean –
7 A. It — it became the other way around
9 Q. You did more signing than processing?
10 A. Correct.
11 Q. Okay. Does that continue to today?
12 A. No. I’m in a different department.
13 Q. What department are you in now?
14 A. I’m in document inspection.
15 Q. What does a document inspector do?
16 A. I’m making sure that everything is completed
17 and ready to be sent to the County: Ensure all the
18 signatures, stamps, the mortgage has all the pages,
19 et cetera.
20 Q. Just basically a quality control job?
21 A. Right.
22 Q. Okay. Sir, what I’m going to do is I’m going
23 to — I’ve premarked some exhibits and given them to
24 your lawyer to review. I’m going to give you a copy of
25 the four exhibits I’ve gotten and ask you to refer to
1 them, and they’re tabbed for you.
2 A. Okay.
3 MR. RODEMS: This is my copy?
4 MR. KORTE: That’s your copy.
5 MS. POLLAN: While we’re on a break real
6 quick, do you mind if you can maybe move the phone
7 a little closer? I’m having a hard time hearing
9 MR. KORTE: We’ll try.
10 MS. POLLAN: Okay. Thank you.
11 MR. KORTE: Are you having a hard time hearing
12 me or Mr. Bly?
13 MS. POLLAN: I can hear you better now, but
14 it’s mostly Mr. Bly.
15 MR. KORTE: All right. It’s closer.
16 MS. POLLAN: Thank you.
17 BY MR. KORTE:
18 Q. All right, sir. Well, you were sent a
19 subpoena duces tecum, which is at Tab 1 of the
20 exhibits. It’s Exhibit 1. If you’d do me a favor and
21 turn to that now.
22 A. Okay.
23 Q. You were asked to bring several documents with
24 you today; is that correct, sir?
25 A. Yes.
1 Q. Okay. And did you bring any documents with
3 A. No.
4 Q. Why not?
5 A. They’re not applicable to what I’m doing.
6 Q. Okay.
7 MR. RODEMS: Well, let’s be clear. He doesn’t
8 have custody, possession, or control of these
10 MR. KORTE: Okay. Is that — are you
11 objecting to his answer, or are you objecting to
12 the question?
13 MR. RODEMS: No. I’m just trying to make the
14 record clear. It’s not — he’s not refusing to
15 produce it. He doesn’t have custody, control, or
16 possession of the documents you’ve requested.
17 THE WITNESS: Correct.
18 BY MR. KORTE:
19 Q. Well, let’s start with No. 1, sir. Do you
20 have any documents that are requested in No. 1 in your
21 custody or control?
22 A. No, I haven’t.
23 Q. Okay. Have you ever had those documents in
24 your custody or control?
25 A. No.
1 Q. Can you get those documents?
2 A. No.
3 Q. Okay. Let’s talk about No. 2 on the list, on
4 the duces tecum. Do you have any documents that are
5 responsive to that in your custody or control?
6 A. No.
7 Q. Have you ever had any in your custody or
9 A. No.
10 Q. Okay. As to No. 3, employment records, do you
11 have any employment records in your custody or control?
12 A. No.
13 Q. Have you ever had any employment record in
14 your custody and control?
15 A. No.
16 Q. Did you make any effort to get any of those
17 employment records before coming here today?
18 A. No.
19 Q. Why not?
20 MR. RODEMS: Wait. That’s going to invade the
21 attorney-client privilege, so I’m going to
22 instruct him not to answer.
23 BY MR. KORTE:
24 Q. Other than discussions with your lawyer or
25 instructions from your lawyer, is there a reason why
1 you didn’t bring employment records with you today?
2 A. I’m not in possession of them. That’s the
3 personnel. They’re — they’re the custodian of those.
4 Q. Did you go to the personnel department and ask
5 them for those records?
6 MR. RODEMS: Again, that’s invading the
7 attorney-client privilege.
8 MR. KORTE: Whether he went to the personnel
9 department and requested the documents?
10 MR. RODEMS: Oh, that question? No. Okay.
11 You can answer that question.
12 THE WITNESS: No.
13 BY MR. KORTE:
14 Q. As to No. 4, all the records that purport to
15 give you the authority to sign or execute documents on
16 behalf of any person or entity, did you have any of
17 those documents in your possession or control?
18 A. I believe you have the corporate resolutions
20 Q. I don’t, but did you bring those with you
22 MR. RODEMS: Well, he didn’t but I did. I’ll
23 show you what is entitled UNANIMOUS WRITTEN
24 CONSENT OF THE EXECUTIVE COMMITTEE OF THE BOARD OF
25 DIRECTORS OF CITI RESIDENTIAL LENDING, INC., dated
1 November 20th, 2008, and another document entitled
2 LIMITED POWER OF ATTORNEY, which is signed by
3 several individuals; and the dates of signature
4 are October 10th of 2007. I believe those might
5 be responsive to No. 4.
6 BY MR. KORTE:
7 Q. All right, sir. Other than those two
8 documents, are there any other documents that would be
9 responsive to No. 4 that were in your custody or
11 A. No.
12 Q. All right. Where did you get these documents
13 that your lawyer — and I’m going to mark these as
14 Defendants’ 5 and 6, if that’s okay.
15 (Defendants’ Exhibit Nos. 5 and 6 were marked
16 for identification.)
17 BY MR. KORTE:
18 Q. Sir, where did you receive Defendants’ 5 and 6
19 from that you brought here today?
20 A. From I guess it would be — I guess it was
21 Star Hillman, I guess. Any administrator executive
22 level can produce a copy for us.
23 Q. Did you request a copy before coming here
25 A. We were under the assumption that you’ve had
1 them. They’ve been response, but they — they sent
2 them — my lawyer with them.
3 Q. Well, did you ask anybody else to give you any
4 other documents that would be similar to this that
5 would give you authority to sign on any other entity’s
7 A. No.
8 Q. Why not?
9 A. Because it’s not — not relevant. This is on
10 Citi, and it’s not relevant on the other accounts.
11 Q. So you just — you were able to get the ones
12 for Citi. Were you also able to get the ones for other
14 MR. RODEMS: Let me object. These documents
15 were not in his custody, possession, or control at
16 any time. I have obtained those documents, and I
17 have brought them to you. He does not have an
18 obligation to go and ask for documents that are
19 maintained in somebody else’s custody, possession,
20 or control.
21 So I want to make sure the record is clear.
22 I’ve produced them today. They may be responsive
23 to No. 4. You have them. You can certainly
24 question him about them; but to the extent that
25 the record is implying that he produced these
1 today from his request to somebody to get them,
2 that would be a misperception.
3 BY MR. KORTE:
4 Q. Well, then let me ask this very simple
5 question to make it clear: Were these documents,
6 Nos. 5 and 6, Defendants’ Exhibits, in your custody and
7 control at any time?
8 A. No.
9 Q. So how did you come about their possession?
10 MR. RODEMS: Mr. Korte, I just explained to
11 you that I had them. I obtained them from other
12 places. So he’s never had them.
13 MR. KORTE: Well, you’re his agent.
14 MR. RODEMS: Right.
15 MR. KORTE: So he has them.
16 MR. RODEMS: No. I have them.
17 MR. KORTE: Well, I’m not going to play
18 semantics with you. I’m asking if he didn’t get
19 them, he had his agent get them for him.
20 MR. RODEMS: No. He didn’t have me do
21 anything. I have them, and now you have them.
22 MR. KORTE: Well, actually, I don’t.
23 Actually, they were produced under the duces
24 tecum. I want to know what he has in his custody
25 and control.
1 MR. RODEMS: Okay.
2 MR. KORTE: If he’s never had them in his
3 custody and control, then I don’t want them
5 MR. RODEMS: Okay.
6 MR. KORTE: I mean, I can take your deposition
7 right after this one and figure out where you got
8 them from, but I assume that’s not what you want
9 to do.
10 BY MR. KORTE:
11 Q. The duces tecum is directed to you, sir. What
12 documents did you have responsive to that question for
13 me today?
14 A. Oh, I’ve never had custody of these documents
15 or possession.
16 Q. And as to No. 5, sir, what documents did you
17 bring today that were responsive to No. 5 in the duces
19 A. None.
20 Q. All right. So let’s just recap. You have no
21 documents responsive to any of the questions in the
22 duces tecum?
23 A. Correct.
24 Q. Sir, I’m going to ask you to turn to
25 Defendants’ No. 2, which is at Tab 2 in your packet.
1 Are you there, sir?
2 A. Yes.
3 Q. All right, sir. Does your name appear on this
5 A. Yes.
6 Q. Okay. Did you cause your name to be placed on
7 this document, sir?
8 A. I authorized it.
9 Q. All right. So did you — let’s go back to
10 this document itself. This is a copy of a document,
11 correct, it’s not the original document?
12 A. Correct.
13 Q. Why don’t you take me through the process that
14 you go through on a day-to-day basis when you’re doing
15 signing work with an assignment of mortgage like this?
16 MR. RODEMS: I’ll tell you what. I object to
17 that because that’s not relevant. If you want to
18 ask him about this particular document, you can.
19 MR. KORTE: I’m asking him how he does his job
20 on a day-to-day basis.
21 MR. RODEMS: That’s not relevant to this case.
22 MR. KORTE: Well, I’m asking him. If you’re
23 instructing him not to answer, you can do it.
24 You’ve just got to say the words.
25 MR. RODEMS: I am instructing him not to
2 MR. KORTE: Will you let him answer any
3 questions relative to the scope of his work and
4 the way he does his job?
5 MR. RODEMS: Yes, as it relates to the
6 document he produced, which is relevant to this
8 MR. KORTE: Well, just so that we’re clear,
9 sir: You’re not representing Deutsche Bank, are
11 MR. RODEMS: No. Just Mr. Bly.
12 MR. KORTE: Okay. So your relevance to this
13 case — you’re making a determination this isn’t
14 legally relevant to the case itself? Is that your
15 position, sir?
16 MR. RODEMS: Is what illegally what?
17 MR. KORTE: Is — are you saying that his
18 scope of his employment is not relevant to the
19 case of Deutsche Bank vs. Gantt?
20 MR. RODEMS: Yes. That’s what I’m saying.
21 MR. KORTE: You’re making a legal
22 determination of relevance in a case you’re not
23 the lawyer for the plaintiff or the defendant on?
24 MR. RODEMS: No, I don’t have –
25 MS. KENEFIC: The plaintiff is going to make a
1 standing objection as to the relevance of the
2 assignment of mortgage. We understand the
3 assignment of mortgage was part of a composite
4 exhibit to the complaint, but the plaintiff will
5 not be relying upon the assignment of mortgage in
6 order to establish its standing. It will be
7 filing an affidavit of equitable interest.
8 MR. KORTE: I understand. That’s fine. I’m
9 just trying to figure out how the lawyer who
10 doesn’t represent the bank or the defendant is
11 discussing relevance on a document and how it
12 impacts that other case.
13 MR. RODEMS: Well, I — I can’t make that
14 determination, only the judge can, but I can
15 assert the objection; and, if we can’t agree on
16 the procedure, obviously the judge will need to
17 make the decision at some point.
18 But what I would suggest is it’s because I am
19 here to protect my client from harassment,
20 oppression, undue burden, that I object to him
21 discussing his job or anything having to do with
22 his job that’s not relevant to the lawsuit that
23 he’s here on.
24 Just because you filed a lawsuit or defended a
25 lawsuit or however you got here today, Mr. Korte,
1 does not mean you have a right to ask Mr. Bly
2 about anything you choose to.
3 Apparently this document that you’ve marked as
4 Exhibit 3 (sic) to this deposition is relevant to
5 the case, and you may ask him about this document,
6 and you may ask him anything you wish to know
7 about this document; but to ask him generally how
8 he does his job or what he does outside of this
9 case is not relevant, and I’m not going to permit
10 him to answer that because in the past when he has
11 been deposed, that deposition was released
12 publicly, and he was subjected to death threats
13 and threats of bodily harm.
14 So I have a duty to protect him, and I am not
15 making a determination as to relevance. I am
16 objecting on the basis of relevance, subject to
17 the — a Court’s review of it.
18 MR. KORTE: So is my question unduly
19 burdensome, sir, that he can’t tell me what he
20 does in a day at his job?
21 MR. RODEMS: Yes.
22 MR. KORTE: It’s harassing also?
23 MR. RODEMS: Yes. Absolutely.
24 MR. KORTE: And we’re not going to agree that
25 I can talk about how he does his job on a
1 day-to-day basis when he’s signing these
3 MR. RODEMS: Yes, sir. I think we’re in
4 agreement that that’s not something that I’m going
5 to let him go into.
6 MR. KORTE: All right. We’re –
7 MR. RODEMS: But you can ask him about
8 anything you wish to on Exhibit 3.
9 MR. KORTE: Unfortunately, that is basically
10 the core of where my case is going to go,
11 especially with education and background. It’s
12 actually as to 2 which was marked.
13 So I’m going to terminate the deposition at
14 this point in time, and we’ll come back when the
15 judge does a ruling. Have a good afternoon.
16 MR. RODEMS: So it’s clear: You don’t have
17 any intention of asking him the specifics about
18 the document that you’ve attached as Exhibit 3?
19 MR. KORTE: I have tons of expectation –
20 questions to ask about the document itself; but in
21 the context of his day-to-day employment, I’m
22 entitled to take the discovery in the way and the
23 manner I want to –
24 MR. RODEMS: No, you’re not.
25 MR. KORTE: I am.
1 MR. RODEMS: No, you’re not.
2 MR. KORTE: Well, that’s why we’re terminating
3 the deposition.
4 MR. RODEMS: You’re governed by the same Rules
5 of Procedure that I’m going by. I will not stop
6 you from asking any relevant questions about
7 Exhibit 3, and you have a full and fair
8 opportunity to do it.
9 If you choose to terminate the deposition and
10 not ask questions about this, I will ask the judge
11 to not allow you to re-depose my client because
12 that is also harassing and burdensome.
13 MR. KORTE: Well, in this particular case,
14 sir, I’ve asked him about how he does his job when
15 he signs these types of documents, and we’ll get
16 into the specifics of how he signed this
17 particular document thereafter; but, if you’re not
18 going to let me answer — ask questions about how
19 he does his job in this particular case, I’m going
20 to terminate the deposition.
21 If you need to file a protective order or
22 prevent me from taking it in the future –
23 MR. RODEMS: Just so that we’re clear:
24 Exhibit 3 is the assignment of mortgage that
25 Mr. Bly caused to be signed relating to Zaidy
1 Gantt, G-a-n-t-t, and Mr. Bly is prepared to
2 answer whatever questions you may have on this
3 document, including how his signature was placed
4 on this document and the circumstances surrounding
5 this document to the extent he has any knowledge
6 of it.
7 MR. KORTE: Well, I don’t agree that that’s
8 going to be sufficient.
9 MR. RODEMS: Okay.
10 MR. KORTE: We’re off.
11 (Discussion off the record.)
12 THE REPORTER: Do you want to go back on?
13 MR. RODEMS: Yeah. On the record. We do
14 intend to read, and I’d like to mark and attach,
15 as Mr. Bly’s exhibit, a copy of the transcript
16 from the hearing in front of Judge Lazarus,
17 L-a-z-a-r-u-s, dated Tuesday, June 7, 2011.
18 MR. KORTE: All right. We’re done.
19 (Deposition terminated at 2:12 p.m.)
20 (Bly’s Exhibit No. 1 was marked for
1 CERTIFICATE OF OATH
4 STATE OF FLORIDA
5 COUNTY OF HILLSBOROUGH
8 I, Lisa A. Simons-Clark, RPR, CRR, Notary
9 Public, State of Florida, certify that BRYAN BLY
10 personally appeared before me on the 18th day of August
11 2011 and was duly sworn.
15 Lisa A. Simons-Clark, RPR, CRR
16 Notary Public – State of Florida
17 My Commission Expires: 7/1/12
18 Commission No. DD 796785
1 REPORTER’S CERTIFICATE
3 STATE OF FLORIDA
4 COUNTY OF HILLSBOROUGH
I, Lisa A. Simons-Clark, Registered
6 Professional Reporter, Certified Realtime Reporter,
certify that I was authorized to and did
7 stenographically report the deposition of BRYAN BLY;
that a review of the transcript was requested; and that
8 the transcript is a true and complete record of my
I further certify that I am not a relative,
11 employee, attorney, or counsel of any of the parties,
nor am I a relative or employee of any of the parties’
12 attorney or counsel connected with the action, nor am I
financially interested in the action.
Dated this ____ day of August 2011.
Lisa A. Simons-Clark, RPR, CRR
21 the foregoing document and that the facts stated in it
24 DATE BRYAN BLY
25 Reporter: Lisa A. Simons-Clark, RPR, CRR