Case 1:15-cv-00293-LTS-RWL Document 175-7 Filed 05/05/17 Page 1 of 7

EXHIBIT G
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�AORB (Rev 1(94} S11hnne1rn m II C'ivil Case

Issued by the
UNITED STATES DISTRICT COURT
Southern DISTRICT OF New York

Mortgage Resolution Servicing, et al. SUBPOENA IN A CIVIL CASE

V.
JPMorgan Chase, N.A., et al.
Case Number:1 15-cv-00293-L TS-JCF

TO: Enka Lance

2100 US-19 ALT, Palm Harbor, FL 34683

D YOU ARE COMMANDED to appear in the United States District court at the place, date, and time specified below to
testify in the above case.
PLACE OF TESTIMONY COURTROOM

DATE AND TIME

[;, YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition
in the above case.
PLACE OF DEPOSITION . · DATE AND TIME
Jung and Sisco PA, 101 East Kennedy Blvd., Suite 3920, Tampa, FL
33602 3/7/2017 9:30 am

[;l YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects at the
place, date, and time specified below (list documents or objects):
See attachment A

PLACE DA TE ANO TIMTI

Jung and Sisco PA, 101 East Kennedy Blvd., Suite 3920, Tampa, FL 33602
3/1/2017 5:00 pm

D YOU ARE COMMANDED to permit inspection ofthc following premises at the date and time specified below.
PREMISES DATE AND TIME

Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or more officers,
directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated,
the matters on which the person will testify. Federal Rules of Civil Procedure, 30(b)(6).

IS�FFI�!:_�!� AN?·-��ICATE !F ATTORNEY FOR PLAINTIFF OR DEFENDANT) DATE

l� / &�� -ft,,-- ?la.i� -H Ns

ISSUING OFFICER'S NAM!.-:, ADDRESS AND PHONE NUMBER
Brent Tantillo, Attorney for Plaintiffs, 1629 K Street, NW, Suite 300, Washington, DC 20006, (786) 506-2991

(Sec Rule 45, Federal Rules of Civil Procedure, Parts C & Don next page)

1
If action is pending in district other than district of issuance, state district under case number.
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R 4 ' 1 n i
PROOF OF SER VICE
DATE
SERVED
SERVED ON (PRINT NAME)
SERVED BY (PRINT NAME)
DECLARATION OF SER VER
I declare under penalty of perjury under the laws of the United Stares of America that the foregoing information contained
in the Proof of Service is true and correct.
Executed on
DATE
Rule 45, Federal Rules of Civil Procedure, Parts C & D:
(c) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS.
(I) A party or an attorney responsible for the issuance and service of a
subpoena shall take reasonable steps to avoid imposing undue burden or expense
on a pctvon subject to that subpoena. The court on behalf of which the subpoena
was issued shall enforce this duly and impose upon the party or attorney in breach
ofttus duty an appmpnate sanction which may include, but is not limited to, lost
c<1rn111gs and reasonable attorney's fee.
(2) (A) A person commanded to produce and perrmt inspection and copying
of designated hooks, papers, documents or Iangjblc things, or inspection of
premises need not appear in person at the place of production or inspection unless
commanded to appear for deposition, hearing or !rial.
(B) SuhJeCt to paragraph (d) (2) of this rule, a person commanded to
produce and permit inspection and copying may, within 14 days after service of
subpoena or before the time speci tied for compliance if such time is less than ! 4
days after service, serve upon the party or attorney designated in the subpoena
wntlcn objccnon to inspection or copying of any oral I oft he designated materials
or of the premises If objection ts made, the party serving the subpoena shall not
be cnntlcd to inspect and copy materials or inspect the premises except pursuant
to an order oft he court by which the subpoena was issued. If objection has been
made, the party serving the subpoena may, upon notice to the person commanded
to produce, move at any time for an order to compel the production. Such an
order to comply production shall protect any person who is not a party or an
officer of a party from significant expense resulting from the inspection and
copying conunandcd.
(3) (A) On nrncly motion, the court by which a subpoena was issued shall
quash or modify the subpoena if it
(1) fails to allow reasonable time for compliance,
(ti} requires a person who is not a party or an officer ofa party to
travel ton place more than 100 miles from the place where that person resides, is
employed or regularly transacts business in person, except that, subject to the
provisions of clause (c) (3) (B) (iii) of tbis rule, such a person may in order to
attend
PLACE
MANNER or SERVICE
TITLE
S[GNATURE OF SERVER
ADDRESS OF SERVER
trial be commanded to travel from any such place within the state in which the
trial 1.� held, or
(111) requires disclosure of privileged or other protected matter and
no exception or waiver applies, or
(iv) suhJeCI� a person !o undue burden
(R) lfa subpoena
(i) requires disclosure of a trade secret or other confidential
research, development, or commercial information, or
(11) requires disclosure of an unrctaincd expert's opinmn or
information not describing specific events or occurrences in dispute and resulting
from the expert's study made not at the request of any party, or
{iii) requires a person who is not a party or an officer ofa party to
mcur substantial expense to travel more than 100 miles to attend met, the court
may, to protect a person subject to or affected by the subpoena, quash or modify
the subpoena, or, if the party in who behalf the subpoena rs issued shows II
substantial need for the testimony or material that cannot be othenvisc met
without undue hardship and assures thnt the person to whom the subpoena is
addressed will be reasonably compensated, the court may order appearance or
production only upon specified conditions.
(d) DUTIES IN RESPONDING TO SUBPOENA.
(!)A person responding to a subpoena to produce documents shall produce
them as they are kept in the usual course of business or shall organize and label
them to correspond with the categories in the demand
(2} When informmion subject to a subpoena rs withheld on a claim that it is
pri vi!eged or subject to protection as trial preparation materials, the claim shall be
made expressly and shall be supponed by a description of the nature of the
documents, communications, or things not produced that is sufficient to enable the
mmmdcmendmg party lo contest the claim.
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DEFINITIONS ANO INSTRUCTIONS

The definitions and rules of construction set forth in Federal Rule of Civil Procedure 34

and Local Civil Rule 26.3 are incorporated and apply to this Subpoena. These definitions apply

throughout the

Subpoena without regard to capitalization.

1. The terms "document," "communication," "concerning," "identify," and "person" have

the meanings set faith in Local Civil Rule 26.3.

2. "Local Civil Rules" means the Local Civil Rules of the United States District Court for

the Southern District of New York.

3. The terms "relating to" and "regarding" shall mean concerning, relating to, referring

to, reflecting, regarding, describing, involving, evidencing or constituting,

4. The terms "TAC" and "Third Amended Complaint" shall mean the complaint filed by

the Plaintiffs in the above-captioned action on August 24, 2015 (ECF No. 67), attached.

5. The terms "Defendants" or "Chase" refer to JPMorgan Chase Bank, N.A., JPMorgan

Chase & Co., and Chase Home Finance LLC, and each of their predecessors, successors, assigns,

divisions, subsidiaries and affiliates; each other person directly or indirectly, wholly or in part,

owned or controlled by them or any of them; each partnership or joint venture to which any of

them is a party; and all present and former directors, officers, employees, agents, consultants, or

other persons acting on behalf of them or any of them.

6. The term "You", "Your" or "NTC" refers to Nationwide Title Clearing, Inc. and each of

its predecessors, successors, assigns, divisions, subsidiaries and affiliates; each other person

directly or indirectly, wholly or in part, owned or controlled by them or any of them; each

partnership or joint venture to which any of them is a patty; and all present and former directors,
 Case 1:15-cv-00293-LTS-RWL Document 175-7 Filed 05/05/17 Page 5 of 7

officers, employees, agents, consultants, or other persons acting on behalf of them or any of

them.

7. To bring within the scope of these requests all documents that might otherwise be

construed to be outside of their scope, the following rules of construction apply: (i) the

masculine, feminine, or neuter pronoun shall not exclude other genders; (ii) the word "including"

shall be read to mean "including without limitation"; (iii) the present tense shall be construed to

include the past tense and vice versa; (iv) references to employees, officers, directors or agents

shall include both current and former employees, officers, directors and agents; (v) the terms

'<and," ""or," "all," "any," and "each" shall be construed in accordance with Local Civil Rule

26.3; and (vi) in accordance with Local Civil Rule 26.3, the use of the singular form of any word

includes the plural and vice versa.

INSTRUCTIONS

l. Unless otherwise stated, the responsive period for each request is from January, 2007

to the present.

2. This subpoena calls for the production of responsive documents in Your possession,

custody, or control, including but not limited to any of Your respective employees, agents,

attorneys or other persons acting or purporting to act on Your behalf, regardless of location.

3. For the purpose of reading, interpreting, or construing the scope of these requests, the

terms used shall be given their most expansive and inclusive interpretation.

4. Unless instructed otherwise, each request shall be construed independently and not by

reference to any other request for the purpose of limitation or exclusion.

5. If any portion of a document is responsive to any request, the entire document shall be

produced.
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6. You must respond to each request for production separately and fully,

unless it is objected to, in which event the reasons for objection should be

specifically and separately stated.

7. You must produce responsive documents as they are\have been kept in the ordinary

course of business or organize and label them to correspond to the enumerated requests of this

demand.

8. If in answering these requests You claim any ambiguity in interpreting either a request

or a definition or instruction applicable thereto, You shall not use that claim as a basis for

refusing to respond but rather You shall set forth as part of Your response to such request the

language deemed to be ambiguous and the interpretation chosen to be used in responding to the

request.
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Case 1:15-cv-00293-LTS-RWL Document 175-7 Filed 05/05/17 Page 7 of 7

ATTACHMENT A

1. Any and all documentation for the preparation of "Vacation(s) and Rescission of
Modifications of Mortgage" and "Vacation(s) and Rescissions of Lien Release".

2. All contractual agreements between JPMC and NTC beginning Jan 1,2005 through
December 31, 2016.

3. All contractual agreements between MERS and NTC beginning Jan 1,2005 through
December 31, 2016.

4. All contractual agreements between JPMC, as Nominee for MERS and NTC beginning
Jan 1,2005 through December 31, 2016.

5. All corporate resolutions during the above referenced period, which give JPMC
and/JPMC, as Nominee for MERS, the authority to execute documents on behalf of the
aforementioned, such as corporate resolutions and/or certificates of incumbency MERS.