IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF FLORIDAORLANDO DIVISION
ABDIEL ECHEVERRIA &ISABEL SANTAMARIAPlaintiffs,
Case No. 6:10-cv-01933-JA-DAB
v.BAC HOME LOANS SERVICING, L.P, andBANK OF AMERICA, N.ADefendants,
PLAINTIFF'S MEMORANDUM IN SUPPORT OF SUBPOENA DUCES TECUMREQUESTING RESIDENTIAL TELEPHONE RECORDS
COMES NOW, The Plaintiffs Abdiel Echeverria and Isabel Santamaria Pro Se, respectfully move thiscourt enter an order GRANTING the Issuance of a Subpoena Duces Tecum for the production of residential telephone records that are relevant to this case and hereby submit this Memorandum inaccordance to Rule 45 of the Federal Rules of Civil Procedure and Florida Rules of Civil Procedure
RULE 1.410 SUBPOENA.
RULE 1.351. PRODUCTION OF DOCUMENTS AND THINGSWITHOUT DEPOSITION.
Defendant “Bank of America” (BAC) is a financial corporation which utilizes the telephone systemin order to contact their customers and clients. Bank of America has argued that they are not a “debtcollector” even though their mail communications state otherwise. The Defendant has established an -1-