Preview
FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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DEUTSCHE BANK NATIONAL TRUST Index Nos.:
COMPANY AS TRUSTEE FOR AMERICAN 110570-2010
HOME MORTGAGE ASSETS TRUST 2007-1 107031-2009
MORTGAGE-BACKED PASS-THROUGH 107030-2009
CERTIFICATES, SERIES 2007-1 107028-2009
107017-2009
Plaintiff, 105819-2009
-against- PLAINTIFF'S FIRST SET
OF INTERROGATORIES
ROYAL BLUE REALTY HOLDINGS, INC., ET AL., (CONSOLIDATED)
Defendants.
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PLEASE TAKE NOTICE that pursuant to CPLR § 3130, the plaintiff DEUTSCHE
BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR AMERICAN HOME MORTGAGE
ASSETSTRUST 2007-1 MORTGAGE-BACKED PASS-THROUGHCERTIFICATES, SERIES 2007-1
("Plaintiff"
in the cases under the index numbers above ("Plaintiff"), by its attorneys McCabe Weisberg &
Conway, LLC and Ganfer & Shore, LLP, hereby demands that defendant ROYAL BLUE
REALTY HOLDINGS, INC. answer the following interrogatories, separately and fully, in
writing and under oath, within thirty (30) days of receipt of this demand.
DEFINITIONS AND INSTRUCTIONS
1. Any and all descriptions or examples of documents provided hereinafter are illustrative
only and do not limit the request to those particular documents or types of documents, as
to"
if itwere explicitly noted that such request was "not limited the stated examples.
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2. The term Defendant shall mean Royal Blue Realty Holdings, Inc., and its agents,
employees, officers, directors, accountants, representatives or any other person acting on
itsbehalf as well as any parent, subsidiary and affiliate.
3. Building shall mean the premises commonly known as 162-174 Christopher Street a/k/a
130-132 Barrow Street, New York, New York 10014.
"document"
4. The term shall include (without limitation) writings, drawings, graphs,
charts, photographs, phono-records, bills,invoices, shipping documentation, order forms,
purchase orders, bills of lading, e-mails, electronic records, computer disks, and other
data compilations from which information can be obtained and translated, if necessary,
by Plaintiff through detection devices into reasonably usable form, physical objects, and
things.
"person"
5. The word shall mean any natural person, corporation, partnership, firm,
association, joint venture or sole proprietorship. Unless otherwise stated, all references to
corporations or other legal entities (including, without limitation, the parties to this
action) shall encompass allpredecessor or successor corporations or other legal entities;
and all past or present shareholders, directors, officers, trustees, agents, employees,
representatives, and, where not privileged, in-house or outside legal counsel for such
corporations or other legal entities.
documents"
6. The term "all includes each and every document that refers, reflects, or
relates, directly or indirectly, in whole or in part, to the subject matters described in a
given document request. Where originals were not available, authentic copies of such
documents may be produced; but, ifa document has been prepared in separate copies, or
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additional copies have been made and the copies are not identical (or which, by reason of
subsequent modification of a copy or by the addition of notations, are no longer
identical), each non-identical copy is a separate document and should be identified or
produced.
to" to"
7. The terms "refer and "relate request all documents and tangible things which in
any way explicitly or implicitly refer to, or could be reasonably construed to refer to, the
subject matter of the request, including, but not limited to, all documents and tangible
things which reflect, record, memorialize, discuss, consider, review, show, mention,
analyze, indicate, contain, identify, incorporate, deal with, report on the subject matter of
the request, speak of in any way, or pertain to in any way.
"communication" "communications"
8. The terms and means any transmission of
information, in any form, via any medium, including, e-mail, facsimile, digital or
electronic messaging, mailings and any other transmission from any person or persons to
any other person or persons. In the case of information transmitted by means of a
"communication"
document, includes any copy of such document and any other
document incorporating, summarizing, or describing the contents of the transmission. In
the case of information transmitted by any other means (e.g., orally or electronically),
"communication"
includes any document containing a recording, transcription, summary
or description of the transmission or identifying the time, place, subject matter, medium
of transmission and/or participants in the transmission.
9. The phrasing of these interrogatories shall be construed so as to make Defendant's
"including"
responses inclusive rather than exclusive. Thus, the word is intended to be
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to."
comprehensive and means "including but not limited Similarly, the singular form of
all words includes the plural form and plural form of all words includes the singular
"and" "or"
form; the words and shall be interpreted as both conjunctive and disjunctive;
"any" "each"
the word shall mean "any and all"; and the word shall mean "each and
every."
10. If Defendant objects to any of these interrogatories, then Defendant(s) shall state the
reasons for each such objection. If Defendant objects to any part of an interrogatory, then
Defendant shall further specify the part. Similarly, if Defendant does not object to a
particular interrogatory, but is unable to comply fully with that request, then Defendant
shall comply to the fullest extent possible and provide an explanation for the lack of full
compliance.
11. If any information responsive to an interrogatory is unavailable because ithas been lost,
discarded, or destroyed, please summarize for each such document: (a) the nature of the
document and itscontents, (b) the identity of the author, (c) the date written or originated,
(d) the identity of each person to whom the original or a copy was addressed and/or
delivered, (e) the identity of every other person who has ever had possession of the
original or a copy of the documents and (f) the date, ifpossible, on which the document
was lost, destroyed, or transferred voluntarily or involuntarily to others, and (g) if
destroyed or transferred, the conditions of and reasons for such destruction or transfer,
and the person(s) requesting or performing such destruction or transfer.
12. All of these interrogatories are directed not only to information in the possession,
custody, or control of Defendant, but also to information in the possession, custody, or
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"person"
control of any (as defined herein) that Defendant controls and to any
information in the possession, custody or control of any directors, officers, trustees,
and - unless privileged - legal counsel of such
agents, employees, representatives, any
person. In addition, information for which Defendant has the legal right to obtain shall be
considered within each person's possession, custody or control..
13. The interrogatories which follow are to be considered continuing, and Defendant is
requested to provide, by way of supplementary responses thereto, such additional
responses and/or additional information as each person or any persons acting on his/her
behalf may hereafter obtain which is related to any of the requests for the responses
contained herein. Such supplemental responses are to be served upon counsel for Plaintiff
within twenty (20) days after Defendant knows, or should know, of such additional
documents.
INTERROGATORIES
INTERROGATORY NO. 1: Identify any and all known or potential beneficiaries, heirs, or
potential heirs of Serge Souto including, for each, the nature of their relationship to Serge Souto
and the nature of their inheritance, if known.
INTERROGATORY NO. 2: Identify any and all known or potential beneficiaries, heirs, or
potential heirs of John Souto including, for each, the nature of their relationship to John Souto
and the nature of their inheritance, if known.
INTERROGATORY NO. 3: Identify the State and the county or counties where the estate of
John Souto is or was being probated, administered, or otherwise determined.
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INTERROGATORY NO. 4: Identify the State and the county or counties where the estate of
Serge Souto is or was being probated, administered, or otherwise determined.
INTERROGATORY NO. 5: Identify each and every pending and closed surrogate's
proceeding or comparable estate proceeding related to the estate of Serge Souto, including for
each, the court, index number, date such proceeding was commenced and the status of the
proceeding. If no such proceeding(s) have been commenced, state why.
INTERROGATORY NO. 6: Identify each and every pending and closed surrogate's
proceeding or comparable estate proceeding related to the estate of John Souto, including for
each, the court, index number, date such proceeding was commenced and the status of the
proceeding. If no such proceeding(s) have been commenced, state why.
INTERROGATORY NO. 7: State whether letters testamentary, letters of trusteeship and/or
letters of administration (including, without limitation, preliminary letters) or similar
authorization documents have been granted or issued for the Estate of Serge Souto, including, if
so, (a) what issued; (b) to whom, (c) when, and (d) identify any change in status after the
identified letters or authorization documents issued including if they have been revoked or
amended. If no such letters or authorization documents have issued, state the reason why.
INTERROGATORY NO. 8: State whether letters testamentary, letters of trusteeship and/or
letters of administration (including, without limitation, preliminary letters) or similar
authorization documents have been granted or issued for the Estate of John Souto, including, if
so, (a) what issued; (b) to whom, (c) when, and (d) identify any change in status after the
identified letters or authorization documents issued including if they have been revoked or
amended. If no such letters or authorization documents have issued, state the reason why.
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INTERROGATORY NO. 9: Identify an appropriate contact person, including address,
telephone number and email, for all surrogate or comparable estate proceedings in relation to
the estate of Serge Souto.
INTERROGATORY NO. 10: Identify an appropriate contact person, including address,
telephone number and email, for all surrogate or comparable estate proceedings in relation to
the estate of John Souto.
INTERROGATORY NO. 13: Identify each and every person or entity with a current or prior
ownership interest or management position in Royal Blue Realty Holdings, Inc., including for
each, the nature and extent of such interest, when such interest and/or position began and, if
applicable, ended, and identify their position.
INTERROGATORY NO. 14: Identify any and all persons with authority over or authority to
represent the estate of Serge Souto not otherwise identified in response to Interrogatory No. 7,
including for each the nature and source of that authority.
INTERROGATORY NO. 15: Identify any and all persons with authority over or authority to
represent the estate of John Souto not otherwise identified in response to Interrogatory No. 8,
including for each the nature and source of that authority.
INTERROGATORY NO. 16: Identify Royal Blue's accountant and the person responsible for
paying Royal Blue's bills for the period from 2006 to present.
INTERROGATORY NO. 17: Identify any subsidiaries, divisions, parent companies, or
affiliates of Royal Blue Realty Holdings, Inc.
INTERROGATORY NO. 18: Identify each and every attorney for Defendant and their role as
attorney for Defendant.
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INTERROGATORY NO. 20: State the name of any and all persons, other than your
attorneys, who were consulted or participated in the preparation of the answers to these
interrogatories. As to each such person, identify:
(a) the specific interrogatories on which such individuals were consulted or
participated in preparing;
(b) his or her relationship to Defendant
(c) his or her business address and telephone number;
(d) the length of the person's relationship with Defendant.
INTERROGATORY NO. 21: Identify each and every person who has knowledge or
information relevant to the allegations, averments, admissions, defenses, denials, or counterclaim
contained in Defendant's Answer, including, without limitation, for each person named, the full
name, business and personal address, and business or personal phone number for each, and a
description of his/her relationship to Defendant. For each person named, give a detailed
description of the facts possessed.
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PLEASE TAKE NOTICE that all of the above interrogatories are continuing and an
objection will be made at trial to any response to which is not provided in response hereto, or at
any subsequent time prior to trial.
Dated: New Rochelle, New York McCABE, WEISBERG & CONWAY, LLC
March 30, 2018
/,>
/
/«/'/ /.'~
By: Matthev zotte, Esq.
Attorneys fo laintiff
145 Huguenot Street, Suite 210
New Rochelle, New York 10801
Tel: 914.636.8900
Fax; 914.636.8901
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Index Nos.: 105819-
110570-2010; 107031-2009; 107030-2009; 107028-2009; 107017-2009;
2009
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR
AMERICAN HOME MORTGAGE ASSETS TRUST 2007-1 MORTGAGE-
BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-1
Plaintiff,
-against-
ROYAL BLUE REALTY HOLDINGS, INC., ET AL.,
DEFENDANTS.
PLAINTIFF'S FIRST SET OF INTERROGATORIES
McCABE, WEISBERG AND CONWAY, LLC
Attorneys for Plaintiff
145 Huguenot Street, Suite 210
New Rochelle, New York 10801
914.636.8900
914.636.8901 facsimile
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Preview
FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------X DEUTSCHE BANK NATIONAL TRUST Index Nos.: COMPANY AS TRUSTEE FOR AMERICAN 110570-2010 HOME MORTGAGE ASSETS TRUST 2007-1 107031-2009 MORTGAGE-BACKED PASS-THROUGH 107030-2009 CERTIFICATES, SERIES 2007-1 107028-2009 107017-2009 Plaintiff, 105819-2009 -against- PLAINTIFF'S FIRST SET OF INTERROGATORIES ROYAL BLUE REALTY HOLDINGS, INC., ET AL., (CONSOLIDATED) Defendants. --------------------------------------------------------------------X PLEASE TAKE NOTICE that pursuant to CPLR § 3130, the plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR AMERICAN HOME MORTGAGE ASSETSTRUST 2007-1 MORTGAGE-BACKED PASS-THROUGHCERTIFICATES, SERIES 2007-1 ("Plaintiff" in the cases under the index numbers above ("Plaintiff"), by its attorneys McCabe Weisberg & Conway, LLC and Ganfer & Shore, LLP, hereby demands that defendant ROYAL BLUE REALTY HOLDINGS, INC. answer the following interrogatories, separately and fully, in writing and under oath, within thirty (30) days of receipt of this demand. DEFINITIONS AND INSTRUCTIONS 1. Any and all descriptions or examples of documents provided hereinafter are illustrative only and do not limit the request to those particular documents or types of documents, as to" if itwere explicitly noted that such request was "not limited the stated examples. 1 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 2. The term Defendant shall mean Royal Blue Realty Holdings, Inc., and its agents, employees, officers, directors, accountants, representatives or any other person acting on itsbehalf as well as any parent, subsidiary and affiliate. 3. Building shall mean the premises commonly known as 162-174 Christopher Street a/k/a 130-132 Barrow Street, New York, New York 10014. "document" 4. The term shall include (without limitation) writings, drawings, graphs, charts, photographs, phono-records, bills,invoices, shipping documentation, order forms, purchase orders, bills of lading, e-mails, electronic records, computer disks, and other data compilations from which information can be obtained and translated, if necessary, by Plaintiff through detection devices into reasonably usable form, physical objects, and things. "person" 5. The word shall mean any natural person, corporation, partnership, firm, association, joint venture or sole proprietorship. Unless otherwise stated, all references to corporations or other legal entities (including, without limitation, the parties to this action) shall encompass allpredecessor or successor corporations or other legal entities; and all past or present shareholders, directors, officers, trustees, agents, employees, representatives, and, where not privileged, in-house or outside legal counsel for such corporations or other legal entities. documents" 6. The term "all includes each and every document that refers, reflects, or relates, directly or indirectly, in whole or in part, to the subject matters described in a given document request. Where originals were not available, authentic copies of such documents may be produced; but, ifa document has been prepared in separate copies, or 2 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 additional copies have been made and the copies are not identical (or which, by reason of subsequent modification of a copy or by the addition of notations, are no longer identical), each non-identical copy is a separate document and should be identified or produced. to" to" 7. The terms "refer and "relate request all documents and tangible things which in any way explicitly or implicitly refer to, or could be reasonably construed to refer to, the subject matter of the request, including, but not limited to, all documents and tangible things which reflect, record, memorialize, discuss, consider, review, show, mention, analyze, indicate, contain, identify, incorporate, deal with, report on the subject matter of the request, speak of in any way, or pertain to in any way. "communication" "communications" 8. The terms and means any transmission of information, in any form, via any medium, including, e-mail, facsimile, digital or electronic messaging, mailings and any other transmission from any person or persons to any other person or persons. In the case of information transmitted by means of a "communication" document, includes any copy of such document and any other document incorporating, summarizing, or describing the contents of the transmission. In the case of information transmitted by any other means (e.g., orally or electronically), "communication" includes any document containing a recording, transcription, summary or description of the transmission or identifying the time, place, subject matter, medium of transmission and/or participants in the transmission. 9. The phrasing of these interrogatories shall be construed so as to make Defendant's "including" responses inclusive rather than exclusive. Thus, the word is intended to be 3 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 to." comprehensive and means "including but not limited Similarly, the singular form of all words includes the plural form and plural form of all words includes the singular "and" "or" form; the words and shall be interpreted as both conjunctive and disjunctive; "any" "each" the word shall mean "any and all"; and the word shall mean "each and every." 10. If Defendant objects to any of these interrogatories, then Defendant(s) shall state the reasons for each such objection. If Defendant objects to any part of an interrogatory, then Defendant shall further specify the part. Similarly, if Defendant does not object to a particular interrogatory, but is unable to comply fully with that request, then Defendant shall comply to the fullest extent possible and provide an explanation for the lack of full compliance. 11. If any information responsive to an interrogatory is unavailable because ithas been lost, discarded, or destroyed, please summarize for each such document: (a) the nature of the document and itscontents, (b) the identity of the author, (c) the date written or originated, (d) the identity of each person to whom the original or a copy was addressed and/or delivered, (e) the identity of every other person who has ever had possession of the original or a copy of the documents and (f) the date, ifpossible, on which the document was lost, destroyed, or transferred voluntarily or involuntarily to others, and (g) if destroyed or transferred, the conditions of and reasons for such destruction or transfer, and the person(s) requesting or performing such destruction or transfer. 12. All of these interrogatories are directed not only to information in the possession, custody, or control of Defendant, but also to information in the possession, custody, or 4 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 "person" control of any (as defined herein) that Defendant controls and to any information in the possession, custody or control of any directors, officers, trustees, and - unless privileged - legal counsel of such agents, employees, representatives, any person. In addition, information for which Defendant has the legal right to obtain shall be considered within each person's possession, custody or control.. 13. The interrogatories which follow are to be considered continuing, and Defendant is requested to provide, by way of supplementary responses thereto, such additional responses and/or additional information as each person or any persons acting on his/her behalf may hereafter obtain which is related to any of the requests for the responses contained herein. Such supplemental responses are to be served upon counsel for Plaintiff within twenty (20) days after Defendant knows, or should know, of such additional documents. INTERROGATORIES INTERROGATORY NO. 1: Identify any and all known or potential beneficiaries, heirs, or potential heirs of Serge Souto including, for each, the nature of their relationship to Serge Souto and the nature of their inheritance, if known. INTERROGATORY NO. 2: Identify any and all known or potential beneficiaries, heirs, or potential heirs of John Souto including, for each, the nature of their relationship to John Souto and the nature of their inheritance, if known. INTERROGATORY NO. 3: Identify the State and the county or counties where the estate of John Souto is or was being probated, administered, or otherwise determined. 5 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 INTERROGATORY NO. 4: Identify the State and the county or counties where the estate of Serge Souto is or was being probated, administered, or otherwise determined. INTERROGATORY NO. 5: Identify each and every pending and closed surrogate's proceeding or comparable estate proceeding related to the estate of Serge Souto, including for each, the court, index number, date such proceeding was commenced and the status of the proceeding. If no such proceeding(s) have been commenced, state why. INTERROGATORY NO. 6: Identify each and every pending and closed surrogate's proceeding or comparable estate proceeding related to the estate of John Souto, including for each, the court, index number, date such proceeding was commenced and the status of the proceeding. If no such proceeding(s) have been commenced, state why. INTERROGATORY NO. 7: State whether letters testamentary, letters of trusteeship and/or letters of administration (including, without limitation, preliminary letters) or similar authorization documents have been granted or issued for the Estate of Serge Souto, including, if so, (a) what issued; (b) to whom, (c) when, and (d) identify any change in status after the identified letters or authorization documents issued including if they have been revoked or amended. If no such letters or authorization documents have issued, state the reason why. INTERROGATORY NO. 8: State whether letters testamentary, letters of trusteeship and/or letters of administration (including, without limitation, preliminary letters) or similar authorization documents have been granted or issued for the Estate of John Souto, including, if so, (a) what issued; (b) to whom, (c) when, and (d) identify any change in status after the identified letters or authorization documents issued including if they have been revoked or amended. If no such letters or authorization documents have issued, state the reason why. 6 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 INTERROGATORY NO. 9: Identify an appropriate contact person, including address, telephone number and email, for all surrogate or comparable estate proceedings in relation to the estate of Serge Souto. INTERROGATORY NO. 10: Identify an appropriate contact person, including address, telephone number and email, for all surrogate or comparable estate proceedings in relation to the estate of John Souto. INTERROGATORY NO. 13: Identify each and every person or entity with a current or prior ownership interest or management position in Royal Blue Realty Holdings, Inc., including for each, the nature and extent of such interest, when such interest and/or position began and, if applicable, ended, and identify their position. INTERROGATORY NO. 14: Identify any and all persons with authority over or authority to represent the estate of Serge Souto not otherwise identified in response to Interrogatory No. 7, including for each the nature and source of that authority. INTERROGATORY NO. 15: Identify any and all persons with authority over or authority to represent the estate of John Souto not otherwise identified in response to Interrogatory No. 8, including for each the nature and source of that authority. INTERROGATORY NO. 16: Identify Royal Blue's accountant and the person responsible for paying Royal Blue's bills for the period from 2006 to present. INTERROGATORY NO. 17: Identify any subsidiaries, divisions, parent companies, or affiliates of Royal Blue Realty Holdings, Inc. INTERROGATORY NO. 18: Identify each and every attorney for Defendant and their role as attorney for Defendant. 7 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 INTERROGATORY NO. 20: State the name of any and all persons, other than your attorneys, who were consulted or participated in the preparation of the answers to these interrogatories. As to each such person, identify: (a) the specific interrogatories on which such individuals were consulted or participated in preparing; (b) his or her relationship to Defendant (c) his or her business address and telephone number; (d) the length of the person's relationship with Defendant. INTERROGATORY NO. 21: Identify each and every person who has knowledge or information relevant to the allegations, averments, admissions, defenses, denials, or counterclaim contained in Defendant's Answer, including, without limitation, for each person named, the full name, business and personal address, and business or personal phone number for each, and a description of his/her relationship to Defendant. For each person named, give a detailed description of the facts possessed. 8 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 PLEASE TAKE NOTICE that all of the above interrogatories are continuing and an objection will be made at trial to any response to which is not provided in response hereto, or at any subsequent time prior to trial. Dated: New Rochelle, New York McCABE, WEISBERG & CONWAY, LLC March 30, 2018 /,> / /«/'/ /.'~ By: Matthev zotte, Esq. Attorneys fo laintiff 145 Huguenot Street, Suite 210 New Rochelle, New York 10801 Tel: 914.636.8900 Fax; 914.636.8901 9 of 10 FILED: NEW YORK COUNTY CLERK 03/30/2018 01:26 PM INDEX NO. 107030/2009 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 03/30/2018 Index Nos.: 105819- 110570-2010; 107031-2009; 107030-2009; 107028-2009; 107017-2009; 2009 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR AMERICAN HOME MORTGAGE ASSETS TRUST 2007-1 MORTGAGE- BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-1 Plaintiff, -against- ROYAL BLUE REALTY HOLDINGS, INC., ET AL., DEFENDANTS. PLAINTIFF'S FIRST SET OF INTERROGATORIES McCABE, WEISBERG AND CONWAY, LLC Attorneys for Plaintiff 145 Huguenot Street, Suite 210 New Rochelle, New York 10801 914.636.8900 914.636.8901 facsimile 10 of 10