DOCUMENTS REQUESTED TO BEPRODUCED AT TRIALREQUEST FOR PRODUCTION NO. 1:
All documents which establish that YOU were the legal, beneficial or equitable owner,and/or mortgagee, trustee, beneficiary or authorized agent of the promissory note and/or Deed of Trust as mandated that is the subject of this action at the time of the non-judicial foreclosure of the Subject Property on February 23, 2006.
REQUEST FOR PRODUCTION NO. 2:
All documents that establish YOUR standing to foreclose on the Subject Property,including but not limited to:A. Copies of all contracts, documents, agreements and other disclosure forms,written communications, notes, memoranda and records concerning the note and mortgage thatare the subject of this action, including attorney fee contracts.B. Copies of all receipts for payments made by or to and/or received by YOUconcerning the note and mortgage that are the subject of this action.
REQUEST FOR PRODUCTION NO. 3:
All assignments, transfers, allonge, or other documents evidencing a transfer, sale or assignment of Defendant’s note, deed of trust, monetary instrument or other document thatsecured payment by Defendant of the loan at issue in this matter from the inception of themortgage loan to the present date.
REQUEST FOR PRODUCTION NO. 4:
All electronic transfers, assignments and sales of Defendant’s note/asset, mortgage, deedof trust or other security instrument.
REQUEST FOR PRODUCTION NO. 5:
All original and intervening Assignments showing a complete chain of assignments fromthe originator to the person assigning the deed of trust and note to YOU.
REQUEST FOR PRODUCTION NO. 6:
All original and intervening receipts of delivery and acceptance of each note showing acomplete chain of such receipts from the originator to the person accepting the document for YOU.
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