In consideration of immunity from suit in cause of
David McCrae, qui tam USAG, and Class,
v.
PHH Corporation and BDFTE, llc
1) BDFTE will surrender all records of trustee
action in case of all mortgage activity in Texas
for the period from November 2009 through
present, as a forensic copy admissible into
evidence, to DOJ.
2) BDFTE will surrender all metadata from
operation of their patented document
processing system from November 2009
through present, as a forensic copy admissible
into evidence, to DOJ
3) BDFTE will supply expert witness service
of their business operation in any court action
regarding the above suit.
4) BDFTE will limit their future practice
to representation of the proprietor only
in any future adversary action brought
by financial institutions or the mortgage
servicer clients.
5) BDFTE will designate David McCrae as
a Board Director representing consumer
affairs. No action will proceed or
client offer of representation made without
specific knowledge and approval of
David McCrae. David will serve a term of
five years, and designate his replacement
and successor during that term.
6) David McCrae will receive no compensation
other than reimbursement for expenses during
service.
7) David McCrae will receive a one time
payment of $1,600,000 as bond of this compact.
for BDFTE: /s/____________
by /s/ David A. McCrae
DATE:_______________________