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Discovery

Discovery

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Published by Carrieonic

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Published by: Carrieonic on May 17, 2009
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05/11/2014

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IN THE SUPREME COURT OF KINGS COUNTYSTATE OF NEW YORKABCPlaintiff Vs. Index No: 12236/07XYZDefendantsDEFENDANTS MOTION REQUESTING PLAINTIFF TO PRODUCEDOCUMENTS, INTERROGATORIES AND ADMISSIONS
COMES NOW DEFENDANT, XYZ, and files this Motion requesting Plaintiffs,ABC, in its capacity as the Lender as per the Mortgage Deed dated 28
th
February 2008to produce the Documents, Interrogatories and Admissions.Request for Production of DocumentsPursuant to the New York Civil Practice Law and Rules Section 3120 the Defendant,Andrea Davilar hereby request that the named Plaintiff, Option One MortgageCorporation to produce the following documents for inspection and copying at alocation within the venue of the Supreme Court of the Kings County, New York,within thirty days of this request. Andrea Davilar asks to be informed of the date, timeand place where the requested documents can be copied by her or her agent or in thealternative, Option One Mortgage Corporation may furnish a legible, true and correctcopy of each requested documents to Andrea Davilar at her mailing address as givenbelow except for the requested Promissory Note are to be served upon Andrea Davilarwithin thirty (30) days after service of this request for production of documents.Andrea Davilar request the Counsel purporting to represent Option One MortgageCorporation, within 30 days of this request for production of these documents, set ahearing with the Court for viewing of the original Promissory Note.Instructions to Request for Production of Documents
 
1.
 
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
Documents Requested
1.
 
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
th
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
th
June 2007. If none, state “none”.
 
3.
 
Produce if any certified or uncertified security used for the funding of thisaccount. If none, state “none”.4.
 
Produce any and all "Pooling Agreement(s)" between the nominal lender at theloan closing and any party or parties who could claim an interest in the loanclosing or documents pertaining thereto and any GSE or other party. If none,state “none”.5.
 
Produce any and all "Deposit Agreement(s)" between the nominal lender at theloan closing and any party or parties who could claim an interest in the loanclosing or documents pertaining thereto and any GSE or other party. If none,state “none”.6.
 
Produce any and all "Servicing Agreement(s)" between the nominal lender atthe loan closing and any party or parties who could claim an interest in theloan closing or documents pertaining thereto and any GSE or other party. If none, state “none”.7.
 
Produce any and all "Custodial Agreement(s)" between the nominal lender atthe loan closing and any party or parties who could claim an interest in theloan closing or documents pertaining thereto and any GSE or other party. If none, state “none”.8.
 
Produce any and all "Master Purchasing Agreement(s)" between the nominallender at the loan closing and any party or parties who could claim an interestin the loan closing or documents pertaining thereto and any GSE or otherparty. If none, state “none”.9.
 
Produce any and all "Issuer Agreement(s)" between the nominal lender at theloan closing and any party or parties who could claim an interest in the loanclosing or documents pertaining thereto and any GSE or other party. If none,state “none”.10.
 
Produce any and all "Commitment to Guarantee Agreement(s)” between thenominal lender at the loan closing and any party or parties who could claim aninterest in the loan closing or documents pertaining thereto and any GSE orother party. If none, state “none”.11.
 
Produce any and all "Release of Document Agreement(s)” between thenominal lender at the loan closing and any party or parties who could claim aninterest in the loan closing or documents pertaining thereto and any GSE orother party. If none, state “none”.

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