Free Statement - District Court of Arizona - Arizona

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1l d.l. hall, attorney, pilc
l l46l4 North Kierland Boulevard, Suite BOO 1
2li Scottsdale, Arizona 85254
1 Telephone: 480.948708-4
31 Facsimile: 480.9-48.3387
Dennis l. Hall, # 013547
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1 Attorneys for Defendants 1.. Gregory and Melanie Brown
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l United States District Court
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1 State of Arizona
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Cathleen Channel, Theresa Case No. CIV 2003-O I OO Pl-IX ROS
10 Wharry, Stacie Hanson, Monique
Nichols, _
11 AFFIDAVIT OF GREG BROWN
Plaintiffs
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v.
13 Assigned to the Honorable Roslyn Silver
Home Mortgage, Inc., an Arizona
14 corporation conducting business in
Arizona; Carl Brown, Molly Brown;
15 Greg Brown; jane Doe Brown; Does (jury Trial Demanded)
l—lO; XYZ Corporations; Black `
16 Partnerships |—X,
17 Defendants. _
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STATE OF ARIZONA ) Cl (dw} EXBL #
is ) ss. DATE "
cmmry Oriviaaeapa 1 GMD -¤¤A5+*. EMR. coe
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211 L. Gregory Brown, being first duly sworn, upon his oath, deposes and states as
22l{ follows: U
23lI l. I make tbis affidavit of my own personal knowledge. l have been asked by counsel
241] for Plaintiffs to address several issues. I do so nntbfully in this afidavit.
Casa? 2:O3—cv—OO100-ROS-IVIEA Document 104-6 Filed 11/O9/2006 Page 1 of 3

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1 2. My fnll name is Lawrence Gregory Brown. I am, and have been, for 28 years, I
2 married to Melanie K. Brown. I
3 3. In early 1999, I closed a business I owned in Kansas City, Mortgage Bark, and I
i 4 I moved to Phoenix to join my father’s business, Home Mortgage, which he had formed in »
5 l I996. Some ofthe branch managers and employees who had worked for Mortgage Bank I
6 I began working for I-Iome Mortgage, and some computers and office equipment was ·
T It contributed to Home. I hoped to work with my father, who had greater assets and I
8 resources; to grow a larger mortgage company.
Q { 4. Initially I worked, primarily, managing the loan officers and branch managers for
10 I I-Iome Mortgage. In 2000 I was named President of Home Mortgage; but, this did not
11 change my responsibilities significantly. Home Mortgage was a family company
12 controlled by my parents. I was the only shareholder except them and I owned, at most,
13 l% of the stock of the Home Mortgage. Over time, as the company needed hands, my
14 I father and mother, Carl and Molly Brown, contributed money to the company which, to-
15 my understanding, diluted my stock interest. I never participated in a shareholder meeting
16 or board meeting, nor did I ever received dividends hom my stock ownership. I believe
17 my parents funded the company with significant amounts of funds from their personal
18 accounts.
19 5. I did not have authority to sign checks on behalf of Home Mortgage and was not
20 involved in managing the finances of the company. It is my understanding that my father,
21 Carl Brown, and my mother, Molly Brown, managed the finances of the company. Iwas
22 not a signatory on any bank accotmt. _ I
23 6. In September, 2002, Home Mortgage sold its assets other than its Phoenix office, I
24 including branch offices in other cities and the ofice equipment associated with those I
25 oftices, to McAfee Mortgage. I handled the sale for Home Mortgage, along with Home’s
Case 2:03-cv—OO100-ROS-IVIEA Document 104-6 Filed 11/O9/2006 Page 2 of 3 ‘

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1 Z attorney, Jeffrey Zimmerman, because McAfee would not deal with Carl Brown. Home J
2 Mortgage received $800,000 from the transaction, which was transferred to account
3 1 #0200I373 at Bank One. I understand that to be an account controlled by Carl and Molly
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4 1 Brown.
5 y 7. _ After the sale to McAfee, I went to work for McAfee and no longer had any
` 6 l relationship with Home Mortgage I have no knowledge about how the funds transferred
- T 1 to McAfee were used by Horne.
8 [ 8. I received all ofthe paychecks owed to me by Home Mortgage.
9 FURTHER AEFIANT SAYETH NAUGHT.
10 I, L. Gregory Brown, swear and affirm, under the penalty of perjury, that the
11 statements made herein are true and correct to the best of rny own personal knowledge.
12 Dated this 6th ofMarch, 2006.
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