Motion to Compel - ATTENDANCE DEPOSITION Due Date: Complete Date: - HSBC BANK USA NATL ASSN VS CAO, ALAN

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On May 28, 2010 a rpmf -homestead ($250,000 or more) case was filed by Hsbc Bank Usa Natl Assn, against Cao, Alan, and Wells Fargo Bank N A, represented by Pomeranz, Mark L, and Richard S Mciver, in the jurisdiction of Miami-Dade County. Judge Jacqueline Hogan Scola presiding.

                        
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                          IN THE CIRCUIT COURT OF THE 11th
JUDICIAL CIRCUIT, INAND FOR
MIAMI-DADE COUNTY, FLORIDA

CASE NO. 10-30754-CA-30
HSBC BANK USA, NATIONAL ASSOCIATION
AS TRUSTEE FOR WELLS FARGO ASSET
SECURITIES CORPORATION, MORTGAGE

PASS-THROUGH CERTIFICATES SERIES
2006-AR14,

Plaintiff,
vs.

ALAN CAO, et. al.,

Defendant(s).

easy Se Udi E182

 

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DEFENDANT'S EMERGENCY MOTION TO COMPEL ATTENDANCE AT DEPOSITION

Defendant, ALAN CAO, et. al. (hereinafter referred to as “Defendant’), by and
through undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, hereby

moves this Honorable Court for the entry of an Order Compelling Plaintiffs Attendance at
Deposition, and as grounds thereof state as follows:

1. Trial is scheduled to occur in this matter on April 30, 2013.

2. Defendant has been attempting to take the deposition of Plaintiff's corporate
representative for almost 3 years, but has been unable to schedule said
deposition through no fault of Defendant.

3.

Defendant initially s…