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Cameron H. Totten, Esq. (SBN 180765) Law Offices of Cameron H. Totten 620 N. Brand Blvd., Ste. 405 Glendale, California 91203 Telephone (818) 483-5795 Facsimile (818) 230-9817 ctotten@ctottenlaw.com Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

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PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 1

) ) PLAINTIFFS, ) ) vs. ) ) SPECIALIZED LOAN SERVICING, LLC; ) MTC FINANCIAL INC., DBA TRUSTEE ) ) CORPS; U.S. BANK NATIONAL ) ASSOCIATION AS INDENTURE ) TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE ) ) TRUST 2007-QHL1 ASSET-BACKED ) SECURITIES, SERIES 2007-QHL1, ) WITHOUT RECOURSE; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, ) INC.;; ALL PERSONS UNKNOWN, ) CLAIMING ANY LEGAL OR EQUITABLE ) RIGHT, TITLE, ESTATE, LIEN, OR ) INTEREST IN THE PROPERTY ) DESCRIBED IN THE COMPLAINT ) ADVERSE TO PLAINTIFFS’ TITLE, OR ) ANY CLOUD ON PLAINTIFFS’ TITLE ) THERETO; and DOES 1-20, INCLUSIVE, ) ) DEFENDANTS. ) ) ) ) ) ) ) )

PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SPECIALIZED LOAN SERVICING, LLC

to that subject.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: PROPOUNDING PARTY: RESPONDING PARTY: LLC. in your actual or constructive possession. INSTRUCTIONS FOR COMPLIANCE WITH THIS REQUEST A. however produced or reproduced. relates to or refers in any way whatsoever. The term “document” or “documents” shall mean all written or graphic materials. members. summaries. 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 be deemed to limit the generality of any such request. custody or control or of any of the officers. notes. either directly or indirectly. D. however denominated. 405. handwritten memorandums or notes. applications.. including all drafts and carbon or photographic copies of any such material. at 620 N. The items hereinafter requested shall be produced at 10:00 a. books. reports. LLC (“Defendant” or “YOU”) produce the following items. memoranda.m. documents and materials now in YOUR possession or under YOUR control and to permit the reproduction of the originals thereof (or copies if the originals cannot be produced) pursuant to CCP Section 2031. Glendale. magnetic or electrical impulse or any other form of communication is recorded or reproduced and includes anything covered by Section 250 of the California Evidence Code. files. interoffice communications. telegrams. the term “writing” refers to papers. change orders. enumerated under “documents requested. letters. C.” including but not limited to files. Ste. or any other printed. PLAINTIFF DEFENDANT SPECIALIZED LOAN SERVICING. letters. agreements. invoices. photostatic copies. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 2 . typewritten or handwritten material of any nature similar to the foregoing. memoranda. agents or employees of their related corporations. logs. Plaintiff (“Plaintiff”) hereby requests that Defendant SPECIALIZED LOAN SERVICING. records.. CA 91203. Brand Blvd. The request for any documents or writings which relate or refer to any subject shall be deemed to request any document or writing which deals with. contracts. contracts.010 et seq. As used throughout this set of requests. The term “Subject Property” shall mean the property commonly known as. on. E. correspondence. minutes of meetings. directors. care. B. papers. representatives. sound recordings or tapes of any conversation or meeting or conference.

3: A copy of the original promissory note signed by Plaintiffs in this matter. SERIES 2007-QHL1. In complying with this request. describe the nature of the document or writing. the date of said document or writing. REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST FOR PRODUCTION NO. H. identify its present custodian and location. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE. you or your attorney or your insurance carriers or anyone subject to your control of anyone else acting in your behalf. papers. REQUEST FOR PRODUCTION NO. and materials in your possession or available to you. ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. you must provide an explanation as to the absence of the originals. state the author or recipient of said document. or if the document or writing still exists. you must make a diligent search of the records. This would include items in the possession or control of other persons directly or indirectly employed by. J. In complying with this request. REQUEST FOR PRODUCTION NO. G.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 F.S. 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. 2: The original promissory note signed by Plaintiffs in this matter. 5: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 3 . K. REQUEST FOR PRODUCTION NO. I. identify its last known custodian and state the date upon which it was lost or destroyed or became unavailable. or connected with. If privilege is claimed as to any requested document or writing. If you can only produce copies but not originals. and specify the privilege claimed. explaining the circumstances and explaining what is being done to obtain the requested items. you are required to furnish all the items asked for which are available to you. If you cannot obtain the requested items in time to comply with this request. In any requested document or writing is known to have existed by no longer exists or is no longer in your possession or control. REQUEST FOR PRODUCTION NO. you may ask for an extension of time. WITHOUT RECOURSE was the legal. 4: All Powers of Attorney for any person signing any of the documents requested herein. 1: All documents which establish that U.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All documents that purport to grant authority to any person to sign any of the documents referred to herein. deed of trust or other security instrument. 7: All documents that establish U. REQUEST FOR PRODUCTION NO. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE. ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. 10: All assignments. REQUEST FOR PRODUCTION NO. including but not limited to: A. REQUEST FOR PRODUCTION NO. notes. REQUEST FOR PRODUCTION NO. 8: All documents that establish the identity of the servicer of Plaintiffs’ mortgage loan that is the subject of this action. 6: The notary registration book for any public notary who certified the signature of any person on any document referred to herein. transfers. REQUEST FOR PRODUCTION NO. agreements and other disclosure forms.S. documents. REQUEST FOR PRODUCTION NO. B. including attorney fee contracts. 11: All electronic transfers. WITHOUT RECOURSE standing to foreclose on the Subject Property. memoranda and records concerning the note and mortgage that are the subject of this action. assignments and sales of Plaintiffs’ note/asset. sale or assignment of Plaintiffs’ note. Copies of all contracts. REQUEST FOR PRODUCTION NO. 9: All contracts between YOU and any person or entity regarding the servicing of the deed of trust and/or note at issue in this matter. or other documents evidencing a transfer. BANK NATIONAL PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 4 . 12: All original and intervening Assignments showing a complete chain of assignments from the originator to the person assigning the deed of trust and note to U. mortgage. monetary instrument or other document that secured payment by Plaintiffs of the loan at issue in this matter from the inception of the mortgage loan to the present date including any such assignment on MERS. state “none”. SERIES 2007-QHL1. written communications. deed of trust. Copies of all receipts for payments made by or to and/or received by YOU concerning the note and mortgage that are the subject of this action. If none.S. allonge.

WITHOUT RECOURSE. ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. SERIES 2007-QHL1. ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE.S. WITHOUT RECOURSE Trust ("the Trust") so as to show a complete chain of endorsements and signed delivery receipts from the originator to the person so endorsing to U. WITHOUT RECOURSE (the Trustee for the Trust).1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ASSOCIATION AS INDENTURE TRUSTEE. REQUEST FOR PRODUCTION NO. SERIES 2007QHL1. WITHOUT RECOURSE. REQUEST FOR PRODUCTION NO.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE. 13: All original and intervening receipts of delivery and acceptance of each note showing a complete chain of such receipts from the originator to the person accepting the document for U. 15: All documents relating to the transfer and assignment of Plaintiffs’ deed of trust and promissory note from the originator of the underlying mortgage note to the depositor for the securitized trust known as THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007QHL1 ASSET-BACKED SECURITIES. 16: All documents relating to the endorsement and delivery of Plaintiff’s mortgage note from the originator there to the depositor for THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES.S. SERIES 2007-QHL1. ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE. REQUEST FOR PRODUCTION NO. WITHOUT RECOURSE. SERIES 2007QHL1. REQUEST FOR PRODUCTION NO. SERIES 2007-QHL1. SERIES 2007-QHL1. WITHOUT RECOURSE Trust ("the Trust") so as to show a complete chain of transfers and assignments from the originator to the person so endorsing to U. 14: All original and intervening endorsements showing a complete chain of endorsements from the originator to the person endorsing Plaintiffs’ note to U. ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. ON BEHALF OF THE HOLDERS OF THE PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 5 .

lenders. preparation. title companies. filed or retrievable under their name or any number. SERIES 2007QHL1. mortgage. memoranda and guidelines given to brokers. assignments and sales of the note or asset. SERIES 2007-QHL1. all agreements. lenders. 22: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 6 . REQUEST FOR PRODUCTION NO. designation or code (such as a transaction number or Social Security number) assigned to them or to the subject transaction(s). refer to or evidence any and all electronic transfers. 18: All documents which relate to. state “none”. 17: All documents relating to the endorsement and delivery of Plaintiffs’ mortgage note from the depositor for THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. records and transaction books maintained by YOU for the mortgage loan at issue in this matter. 21: All documents. including but not limited to all documents relating to the origination. closing agents. and the subject transaction and/or account. and/or any persons who review account files for approval and/or acceptance of assignment. If none. policy and procedure manuals. assignors. disbursement and acceptance of assignment of a residential mortgage loan such as the subject transaction(s). WITHOUT RECOURSE (the Trustee for the Trust). REQUEST FOR PRODUCTION NO. approval or underwriting.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. 20: All documents relating or referring to YOUR policy and practice relating to the origination. 19: All documents (including all computer or digital media-stored data) relating to Plaintiffs. REQUEST FOR PRODUCTION NO. and all instructions. WITHOUT RECOURSE Trust ("the Trust") to the Trustee for the Trust or YOU so as to show a complete chain of endorsements and signed delivery receipts from the depositor for the Trust to the Trustee for the Trust. REQUEST FOR PRODUCTION NO. disbursement. approval. assignment and administration of the loan(s). and all correspondence related to the subject transaction.. the Subject Property. title companies. REQUEST FOR PRODUCTION NO. or which are indexed. including but not limited to all agreements with brokers. deed of trust or other security instrument. symbol. etc. REQUEST FOR PRODUCTION NO.

32: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 7 . All correspondence by and between YOU and either of the Plaintiffs to this action. indemnification agreements. If none. 24: All sales contracts. REQUEST FOR PRODUCTION NO.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MERS. recourse agreements and any agreement related to this account from the inception of this account to the present date. 23: All correspondence by and between YOU and any Defendant to this action with regard to the subject mortgage loan. 29: The Investor Loss Mitigation and Loan Modification Guidelines related to Plaintiffs’ mortgage loan. 31: All account servicing transaction records. electronic or otherwise. REQUEST FOR PRODUCTION NO. 28: The Federal National Mortgage Association (Fannie Mae). REQUEST FOR PRODUCTION NO. transfers. monetary instrument or servicing rights to this mortgage including any such assignments on REQUEST FOR PRODUCTION NO. 30: All documents recording. reflecting or otherwise relating to visits which YOU or YOUR agents made to the Subject Property. REQUEST FOR PRODUCTION NO. 27: All documents and records. allonges. REQUEST FOR PRODUCTION NO. of assignments of this mortgage. REQUEST FOR PRODUCTION NO. 25: The outside and inside front and back of the file folder for Plaintiffs’ loan account. servicing agreements. 26: The entire loan file related to Plaintiffs’ loan for the Subject Property. REQUEST FOR PRODUCTION NO. registers and similar items detailing how Plaintiffs’ account has been serviced from the inception of the account to the present date. Federal Home Loan Mortgage Corporation (Freddie Mac). state “none”. assignments. REQUEST FOR PRODUCTION NO. ledgers. REQUEST FOR PRODUCTION NO. Housing and Urban Development (HUD) Family Servicing Guidelines or any other servicing guidelines used for the servicing of Plaintiffs’ mortgage loan.

payoff calculations. 35: All data. ledgers. If none. any servicers. REQUEST FOR PRODUCTION NO. 34: All account servicing records. draft. state “none”. registers and similar items detailing how Plaintiffs’ account was serviced from the inception of the account to the present date. and documents that relate to the accounting of Plaintiffs’ account from the inception of the account to the present date. transaction histories. statements and documents sent to YOU by previous servicers. If none. accounting records. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. sub-servicers or others in the account file. ARM audits. information. payments records. or any other similar mortgage servicing software used by you. If none. debit or credit notice issued to any servicers of Plaintiffs’ account for payment of any monthly payment. money order. If none.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All letters. fee or expense on the account. other payment. escrow charge. amount and source of all deposits in such accounts and the date. If none. REQUEST FOR PRODUCTION NO. state “none”. figures and information contained in your mortgage servicing and accounting computer systems including. state “none”. notations. 36: All descriptions and legends of all Codes used in YOUR mortgage servicing and accounting system so as to enable the examiners and auditors and experts retained to audit and review this mortgage account to properly carry on their work. or subservicers of Plaintiffs’ mortgage account from the inception of Plaintiffs’ account to the present date. 39: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 8 . interest rate adjustments. state “none”. 37: All account servicing transaction records. payment payoffs. ledgers. REQUEST FOR PRODUCTION NO. text. amount and purpose for all disbursements including the name and address of any party who received any such disbursement. 33: Each and every canceled check. REQUEST FOR PRODUCTION NO. account histories. state “none”. REQUEST FOR PRODUCTION NO. If none. 38: All records for any custodial accounts used for any purpose in connection with Plaintiffs’ mortgage loan including the date. but not limited to Alltel or Fidelity CPI system. state “none”.

statements. data records. reports. collection contacts. extend. 45: Any and all letters. 46: All written property inspection reports and property preservation reports related to the Subject Property. REQUEST FOR PRODUCTION NO. any servicers or sub-servicers of the mortgage from the inception of the account to the present date. calendar reports. 43: All documents which relate to. including all digital photographs or other images of the real property. 41: A complete and itemized statement from the date of the origination of Plaintiffs’ loan to the present of any fees incurred to modify. REQUEST FOR PRODUCTION NO. computer records. documents to or from Fannie Mae and/or Freddie Mac in connection with Plaintiffs’ mortgage loan. adversary proceedings.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All documents and records related to all servicer advances made by any servicer of Plaintiffs’ mortgage loan. or administrative proceedings that have been filed against YOU at any time in the past 60 months for any alleged misconduct related to mortgage servicing or foreclosures. collection reports or other documents generated in connection with the servicing of Plaintiffs’ mortgage loan. refer to or evidence any and all civil actions. arbitrations. or amend the loan or to defer any payment due under the terms of the loan. entries. REQUEST FOR PRODUCTION NO. 40: All documents and records related to all non-recoverable advances made by any servicer of Plaintiffs’ mortgage loan. memos. daily records. 47: All bills and invoices for property inspections for the Subject Property and copies of the front and back of all checks in payment thereof or all confirmed wire transfers in payments thereof. statements and documents contained in Plaintiffs’ account file or imaged by YOU. transfers. 42: All collection notes. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. 44: Any and all correspondence. default reports. REQUEST FOR PRODUCTION NO. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 9 .

You should also produce the front and back of each and every canceled check in payment of each invoice for the charges described herein along with a copy of each respective bill. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. homeowners association dues. taxes. bankruptcy monitoring fees. statement and invoice. and any other assessments in connection with Plaintiffs’ mortgage loan. please attach all emails or electronic messages using NewTrak or any similar communication system regarding such fees and charges. 54: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 10 . hazard insurance. 49: A statement of the past due scheduled principal payments. together with interest thereon at the contract rate. and attach all canceled checks in payment thereof. 51: An itemized statement of all attorneys’ fees incurred at any time since the origination of Plaintiffs’ loan and describe the date and nature of all such services. Such attorney time records should be itemized by the date and nature of the service and the time devoted to each service. appraisal fees. 53: A complete and itemized statement of any late charges to Plaintiffs’ loan from the date of the origination of the loan to the present. 52: A complete and itemized statement from the date of the origination of Plaintiffs’ loan to the present of any property inspection fees. late fees or charges. 48: All invoices for each charge such as inspection fees. 50: An itemized statement of all of the filing fees. past due taxes. broker opinion fees. REQUEST FOR PRODUCTION NO. service fees. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. mortgage insurance premiums. assessments or any expense which was charged to Plaintiffs’ mortgage account from the inception of this account to the present date. advertising and publication expenses and reasonable attorney fees actually incurred with respect to any and all foreclosure proceedings regarding the Subject Property. insurance. attorney fees. appraisal fees. property preservation fees. attaching copies of all bills and invoices. or other similar fees or expenses related in any way to this loan.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. postage. BPOs. Also.

BPO s. on Plaintiffs’ account. 57: Each and every canceled check. and the amount of each monthly default. including but not limited to. 59: All agreements. If none. attorney fees. attorney fees. title searches. REQUEST FOR PRODUCTION NO. state “none”. If none. BPO s and reports done on the Subject Property. commissions or other payments made to anyone in connection with Plaintiffs’ loan. appraisals. 60: All property inspection reports. REQUEST FOR PRODUCTION NO. credit life insurance premiums. taxes. REQUEST FOR PRODUCTION NO. bills. 62: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 11 . REQUEST FOR PRODUCTION NO. appraisal fees. state “none”. REQUEST FOR PRODUCTION NO. cancelled checks and other back-up documentation for such payment. REQUEST FOR PRODUCTION NO. If none. state “none”. insurance. draft or debit notice issued for payment of closing costs. appraisal fees. assessments or any expense which has been charged to Plaintiffs’ mortgage account from the inception of the account to the present date. commissions. appraisal fees. taxes. fees and expenses. 56: All checks used to pay invoices for each charge such as inspection fees. REQUEST FOR PRODUCTION NO. BPO s. attorney fees. insurance.. listed on any and all disclosure statements including. If none. hazard insurance premiums.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 A complete and itemized statement of any and all arrears including each month in which the default occurred. but not limited to. assessments or any expense which has been charged to Plaintiffs’ account from the inception of the account to the present date. 58: All invoices and detailed billing statements from any law firm or attorney that has billed such fees that have been assessed or collected from Plaintiffs’ account from the inception to the present date. title insurance fees. state “none”. 55: All invoices for each charge such as inspection fees. contracts and understandings with vendors that have been paid for any charge on Plaintiffs’ account from the inception of the account to the present date. inspection fees. points. 61: All documents that reflect or relate to fees. etc. contracts. REQUEST FOR PRODUCTION NO.

all receipts by way of payment or otherwise and all charges to the loan in whatever form. 67: All payment receipts. 66: Each and every check issued or received in connection with Plaintiffs’ loan. 68: A complete and itemized statement of the loan transactional history from the date of the origination of Plaintiffs’ loan to the present including. money orders. REQUEST FOR PRODUCTION NO. the nature and purpose of each such debit and credit. 65: All telephone log sheets. 69: All checks and/or wire transfers to any party issued from funds received from any party in connection with Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 63: All bills and invoices for property inspections for the Subject Property and copies of the front and back of all checks in payment thereof or all confirmed wire transfers in payments thereof. 64: Any and all invoices and detailed billing statements from any law firm or attorney that has billed fees that have been assessed to or collected from Plaintiffs’ account from the inception to the present date. REQUEST FOR PRODUCTION NO. internal memoranda. 70: A complete and itemized statement from the date of the origination of Plaintiffs’ loan to the present of any and all debits and credits to any suspense accounts or any other suspense account entries related in any way to his loan. REQUEST FOR PRODUCTION NO. notes or other documents prepared or reflecting activity on Plaintiffs’ account in connection with his loan transaction. commission or payments received by YOU in connection with Plaintiffs’ loan. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 12 . and the name and address of the payee of any type of disbursement related to this account.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All documents relating to any fees. drafts. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. but not limited to. checks. automatic debits and written evidence of payments made by Plaintiffs or others on Plaintiffs’ account. This history should include the date of each and every debit and credit to any account related to this loan.

title insurance fees. points. inspection fees. state “none”. 76: All MORTGAGE ELECTRONIC REGISTRATIONS SYSTEMS.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. ARM audits. state the name of the software system YOU use. including the MIN number. 71: All digital and numerical codes associated with the loan transaction history for Plaintiffs’ loan along with all definitions associated with each such code so as to make the history legible and understandable. account histories. but not limited to. drafts. state “none”. If none. REQUEST FOR PRODUCTION NO. draft or debit notice issued for payment of closing costs. hazard insurance premiums. automatic debits and written evidence of payments made by Plaintiffs’ or others on his account. REQUEST FOR PRODUCTION NO. payment payoffs. state “none”. written assurance or substitution agreement related to any document requested herein. INC. REQUEST FOR PRODUCTION NO. If none. payoff calculations. commissions. modification. credit life insurance premiums. ledgers. 75: All escrow analyses conducted on Plaintiffs’ account from the inception of the account until the present date. REQUEST FOR PRODUCTION NO. 74: Each and every canceled check. REQUEST FOR PRODUCTION NO. 73: All payment receipts. REQUEST FOR PRODUCTION NO. checks. 77: Any and all communications and/or documents evidencing instructions and/or directions that YOU received concerning the non-judicial foreclosure of the Subject Property from any and all other entities. interest rate adjustments. If none. the version. Also. If none. payment records. 79: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 13 . and documents that relate to the accounting of Plaintiffs’ account from the inception of his account to the present date. accounting records. REQUEST FOR PRODUCTION NO. 72: All account servicing records. fees and expenses listed on any and all disclosure statements including. and the name and address of the software provider. 78: Each and every assumption. transaction histories. money orders. appraisal fees. title searches. attorney fees. etc. (MERS) documents related to Plaintiffs’ loan. state “none”.

SERIES 2007-QHL1. 82: All documents or records maintained by any duly appointed custodian who accepted delivery or acknowledged receipt of any document referred to herein on behalf of YOU. REQUEST FOR PRODUCTION NO. so as to show a complete chain of endorsements from the originator to the person so endorsing to THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 14 . REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. with evidence of recording thereon. 88: YOUR entire file related to Plaintiffs’ mortgage loan. 85: The COMMITMENT TO PURCHASE FINANCIAL INSTRUMENT and SERVICER PARTICIPATION AGREEMENT for the HOME AFFORDABLE MODIFICATION PROGRAM under the EMERGENCY ECONOMIC STABILIZATION ACT OF 2008 entered into by YOU and the United States government. REQUEST FOR PRODUCTION NO. including all such endorsements from the date of origination to the present. 80: All endorsements to Plaintiffs’ original note. 87: YOUR entire file related to Plaintiffs. If none. REQUEST FOR PRODUCTION NO. state “none. REQUEST FOR PRODUCTION NO.” REQUEST FOR PRODUCTION NO. WITHOUT RECOURSE trust. 84: All original intervening receipts of delivery and acceptance of each assignment of Plaintiffs’ mortgage loan showing a complete chain of such receipts from the originator to the person accepting the document for YOU. REQUEST FOR PRODUCTION NO. 86: Any and all loan modification agreements entered into between Plaintiffs and Defendants. 81: Plaintiffs’ original deed of trust. 83: All documents in the "mortgage file" for this loan in YOUR possession or any designated custodian. REQUEST FOR PRODUCTION NO.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All written acknowledgments for the receipt of all documents related to Plaintiffs’ mortgage loan executed by YOU.

amounts paid and future interests as a result of the non-judicial foreclosure sale of the Subject Property. REQUEST FOR PRODUCTION NO. refer to or evidence the sale of the Subject Property. refer to or evidence the marketing of the Subject Property. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. DATED: LAW OFFICES OF CAMERON H. Totten Attorney for Plaintiffs PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 15 . 90: Any and all documents which relate to. 93: Any and all documents identified in YOUR responses to Plaintiff’s First Set of Form Interrogatories. after the non-judicial foreclosure of the Subject Property. 89: Any and all documents which relate to. refer to or evidence the non-judicial foreclosure of the Subject Property.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR PRODUCTION NO. refer to or evidence the accounting with regard to debts owed. TOTTEN By: ____________________________ Cameron H. REQUEST FOR PRODUCTION NO. 91: Any and all documents which relate to. 92: Any and all documents which relate to.

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