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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY, FLORIDA

CITIMORTGAGE, INC., )
)
Plaintiff, ) CASE NO.:2010-CA-008798
vs. )
)
MICHAEL J. MILLER, )
)
Defendant(s). )

______________________________________________________________________
DEFENDANT’S REQUEST TO PRODUCE
______________________________________________________________________

COMES NOW the Defendants, MICHAEL J. MILLER, by and through the undersigned

counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, and request Plaintiff to

produce within thirty (30) days of the date of this Request the following documents to the

undersigned law firm of James Dalton, 800 Main St., Logwood, FL 32801, the following:

1. Subject to the foregoing conditions, produce the original promissory note signed by

Defendant Michal J. Miller. If none, state “none.”

2. Produce a copy of the allonge attached to the promissory note obligating Defendant

Michael J. Millershowing an assignment of the promissory note to CITIMORTGAGE

INC.. If none, state “none.”

3. Produce the account and general ledger statement of each and every contract

CITIMORTGAGE INC., alleges the Defendant Michael J. Millerhas with

CITIMORTGAGE INC. If none, state “none.”

4. Produce all bills of sale, and allonges and agreements illustrating where the promissory

note alienable in this instant case was sold or assigned for value. If none, state “none.”

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5. Produce all insurance claim information relative to the alleged loss or destruction of the

promissory note alienable in this instant case. In none, state “none.”

6. Produce all contracts, agreements, and/or memos illustrating that Mary Smith, Esq. or

Morris, Hardwick, Schneider, LLC, has delegated authority to represent

CITIMORTGAGE INC., in this instant case. If none, state “none.”

For all requests: These requests exclude documents that are considered attorney/ client

privilege or attorney work product provided Plaintiff files a list of such documents that are not

produced under protection of attorney/client privilege or attorney work product indicating the

date of the document and the title of each such document or some other means by which to

identify the document which does not disclose any protected or confidential information.

Dated: May 14, 2010

Respectfully Submitted,

____________________________
James Dalton, Esq

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been mailed to
Mary Smith Esq., Morris, Hardwick, Schneider, LLC, 5110 Eisenhower Blvd., Suite 120,
Tampa, FL 33634 on this 14th day of May 2010.

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_________________________
James Dalton, Esq

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