This request for production of documents is directed towards all informationknown or available to Option One Mortgage Corporation includinginformation contained in the records and documents in Option One MortgageCorporations custody or control or available to Option One MortgageCorporation upon reasonable inquiry. Where requested documents does notexist please state the documents does not exist.2.
Each request for production of documents is to be deemed a continuing one. If after serving any requested document, an authorized officer of Option OneMortgage Corporation obtains any further documentation pertaining to thatrequest for production, Option One Mortgage Corporation is requested toserve a supplemental answer setting forth copies of additional documents.Definitions1.
Option One Mortgage Corporation includes any and all persons acting inconcert with Option One Mortgage Corporation.2.
“Document” includes every piece of paper held in Option One MortgageCorporations possession or generated by Option One Mortgage Corporation.3.
“GSE” means Government Sponsored Entity.4.
“MERS” means Mortgage Electronic Registration System.5.
“Nominal Lender” means and includes the Special Purpose Entity which hasbeen constituted by the Option One Mortgage Corporation.6.
“Andrea Davilar” includes all nick names, pseudonyms and / or misnomers inany paper or documents referencing the Defendant or any liability orobligation attributable to her, including Andrea A. Davilar
Subject to the foregoing conditions, produce the original Promissory Notealleged to have been signed by Andrea Davilar as per the loan bearing No:331044918. If none, state “none”.2.
Produce the Order relieving Mr. Leo S. Ortega as the Vice President of Deutsche Bank on or after 19
June 2007 which entitle him to join as the VicePresident of Option One Mortgage Corporation and to sign the Affidavit of Merit and the Amount Due on behalf of Option One Mortgage Corporation on28
June 2007. If none, state “none”.