“Workers in the bank’s wholesale unit added or changed personal information including birth dates, Social Security numbers and addresses for people associated with its business clients in 2017 and early 2018, according to The Wall Street Journal, which cited people familiar with the matter. At the time, the unit was pressed with regulatory deadlines, including one related to anti-money laundering controls.”

EXHIBIT A: “1. Plaintiff, Ditech Financial, LLC (“Ditech”), formerly Greentree Servicing LLC, appears to have willfully violated this Court’s order to produce training manuals. The training manual produced on November 16, 2017, now appears to show that Ditech’s standard business practice does not verify prior servicer’s records for accuracy before boarding loans.

2. The training manual produced appears to show that Ditech’s witness, Christopher Ogden (“Mr. Ogden”), gave false testimony in an effort to introduce the prior servicer’s records into evidence under false pretenses.

3. On June 28, 2017, Mr. Ogden appeared for deposition, gave evasive and incomplete answers, and refused to turn over training materials upon which he relied to give his testimony about the loan boarding process and the creation of business records to be submitted in
evidence at trial under the business records exception to the hearsay rule…”