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RPD One US Bank Form

RPD One US Bank Form

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Published by Cameron Totten
These requests seek documents from the trustee of a mortgage-backed securities fund regarding the fund's standing to foreclose on real property.
These requests seek documents from the trustee of a mortgage-backed securities fund regarding the fund's standing to foreclose on real property.

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Published by: Cameron Totten on May 08, 2010
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09/30/2010

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12345678910111213141516171819202122232425262728Cameron H. Totten, Esq. (SBN 180765)Law Offices of Cameron H. Totten620 N. Brand Blvd., Ste. 405Glendale, California 91203Telephone (818) 483-5795Facsimile (818) 230-9817ctotten@ctottenlaw.comAttorney for Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES
,PLAINTIFFS,vs.1SPECIALIZED LOAN SERVICING, LLC;MTC FINANCIAL INC., DBA TRUSTEECORPS; U.S. BANK NATIONALASSOCIATION AS INDENTURETRUSTEE, ON BEHALF OF THEHOLDERS OF THE TERWIN MORTGAGETRUST 2007-QHL1 ASSET-BACKEDSECURITIES, SERIES 2007-QHL1,WITHOUT RECOURSE; MORTGAGEELECTRONIC REGISTRATION SYSTEMS,INC.; ALL PERSONS UNKNOWN,CLAIMING ANY LEGAL OR EQUITABLERIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTYDESCRIBED IN THE COMPLAINTADVERSE TO PLAINTIFFS’ TITLE, OR ANY CLOUD ON PLAINTIFFS’ TITLETHERETO; and DOES 1-20, INCLUSIVE,DEFENDANTS.)))))))))))))))))))))))))))))))))Case No:
PLAINTIFF’S FIRST SET OFREQUESTS FOR PRODUCTION OFDOCUMENTS TO U.S. BANK NATIONAL ASSOCIATION ASINDENTURE TRUSTEE, ONBEHALF OF THE HOLDERS OF THETERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKEDSECURITIES, SERIES 2007-QHL1,WITHOUT RECOURSE
PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO U.S. BANK 1
 
 
12345678910111213141516171819202122232425262728TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:PROPOUNDING PARTY:PLAINTIFFRESPONDING PARTY: DEFENDANT U.S. BANK NATIONAL ASSOCIATIONAS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWINMORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1,WITHOUT RECOURSEPlaintiff (“Plaintiff”) hereby requests that Defendant U.S. BANK NATIONALASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THETERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE (“Defendant” or “YOU”) produce the following items, papers,documents and materials now in YOUR possession or under YOUR control and to permit thereproduction of the originals thereof (or copies if the originals cannot be produced) pursuant toCCP Section 2031.010 et seq. The items hereinafter requested shall be produced at 10:00 a.m.,on, at 620 N. Brand Blvd., Ste. 405, Glendale, CA 91203.
INSTRUCTIONS FOR COMPLIANCE WITH THIS REQUEST
A.As used throughout this set of requests, the term “writing” refers to papers, books, records, files, letters, memoranda, contracts, invoices, change orders, photostatic copies,magnetic or electrical impulse or any other form of communication is recorded or reproducedand includes anything covered by Section 250 of the California Evidence Code.B.The term “document” or “documents” shall mean all written or graphic materials,however produced or reproduced, in your actual or constructive possession, care, custody or control or of any of the officers, directors, representatives, members, agents or employees of their related corporations, enumerated under “documents requested,” including but not limited tofiles, letters, contracts, agreements, telegrams, memoranda, notes, reports, applications,correspondence, sound recordings or tapes of any conversation or meeting or conference,minutes of meetings, handwritten memorandums or notes, interoffice communications,summaries, logs, or any other printed, typewritten or handwritten material of any nature similar to the foregoing, however denominated, including all drafts and carbon or photographic copiesof any such material.C.The term “Subject Property” shall mean the property commonly known as.
PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO U.S. BANK 2
 
 
12345678910111213141516171819202122232425262728D.The listing of any specific document or writing or categories of documents or writings following any general request herein shall be solely by way of example and shall not bedeemed to limit the generality of any such request.E.The request for any documents or writings which relate or refer to any subjectshall be deemed to request any document or writing which deals with, relates to or refers in anyway whatsoever, either directly or indirectly, to that subject.F.In complying with this request, you are required to furnish all the items asked for which are available to you. This would include items in the possession or control of other  persons directly or indirectly employed by, or connected with, you or your attorney or your insurance carriers or anyone subject to your control of anyone else acting in your behalf.G.In complying with this request, you must make a diligent search of the records, papers, and materials in your possession or available to you.H.In any requested document or writing is known to have existed by no longer exists or is no longer in your possession or control, identify its last known custodian and statethe date upon which it was lost or destroyed or became unavailable, or if the document or writing still exists, identify its present custodian and location.I.If you cannot obtain the requested items in time to comply with this request, youmay ask for an extension of time, explaining the circumstances and explaining what is beingdone to obtain the requested items.J.If you can only produce copies but not originals, you must provide an explanationas to the absence of the originals.K.If privilege is claimed as to any requested document or writing, state the author orecipient of said document, the date of said document or writing, describe the nature of thedocument or writing, and specify the privilege claimed.
REQUESTS FOR PRODUCTION OF DOCUMENTSREQUEST FOR PRODUCTION NO. 1:
All documents which establish that YOU were the legal, beneficial or equitable owner of the promissory note that is the subject of this action at the time of the non-judicial foreclosure of the Subject Property.
REQUEST FOR PRODUCTION NO. 2:
The original promissory note signed by Plaintiffs in this matter.
REQUEST FOR PRODUCTION NO. 3:
PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO U.S. BANK 3
 

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