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Filing # 34849299 E-Filed 11/24/2015 03:58:04 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE!5012974 (11)
WELLS FARGO BANK, NA,
Plaintiff,
VS.
GEORGE T. GOODMAN AND IRMA
OLIVARES, et. al.
Defendants.
i
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
COME NOW the Defendants, GEORGE T. GOODMAN AND IRMA
OLIVARES, by and through undersigned counsel, and pursuant to Florida Rules of Civil
Procedure 1.350, and request Plaintiff, WELLS FARGO BANK, NA, to produce for
inspection and copying at the offices of the undersigned attorney the documents set forth
below on or before the thirtieth (30th) day after service of this Request For Production of
Documents.
I. DEFINITIONS
1. The term "you" or "your" means the party or parties to which this request is
addressed, including attorneys and all other persons acting or purporting to act on behalf of
the party or parties.
2. The term "person" means any natural person, individual, proprictorship,
partnership, corporation, association, organization, joint venture, firm, other business
enterprise, governmental body, group of natural persons, or other entity.
3. The term “document” means any written or graphic matter and other means
of preserving thought or expression and all tangible things from which information can be
processed or transcribed, including the originals and_all non-identical copies, whether
different from the original by reason of any notation made on such copy or otherwise,
including bat not limited to, correspondence, memoranda, notes, messages, letters,
telegrams, teletype, telefax, bulletins, meetings or other communications, inter-office and
intra-office telephone calls, diaries, chronological data, minutes, books, reports, studies,
summaries, pamphlets, bulletins, printed matter, charts, ledgers, invoices, worksheets,
receipts, retums, computer printouts, prospectuses, financial statements, schedules,
affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine or
newspaper articles, releases, graphic or aural records or representations of any kind
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/24/2015 3:58:04 PM.****(including without limitation, photographs, microfiche, microfilm, videotape, records and
motion pictures) and electronic, mechanical or electric records or representations of any
kind (including without limitation, tapes, cassettes, discs and records).
4. The term “all documents” means every document or group or documents as
above defined that are known to you or that can be located or discovered by reasonably
diligent efforts.
5. The term “communication(s)” means every manner or means of disclosure,
transfer or exchange of information, whether in person, by telephone, mail, personal
delivery or otherwise.
6. As used herein, the singuiar shall include the plural, the plural shall include
the singular, and the masculine, feminine and neither shall include each of the genders.
7. When producing the documents, please keep all documents segregated by
the file in which the documents are contained and indicate the name of the file in which the
documents are contained and the name of the documents being produced.
8. When producing the required documents, please produce all other
documents that are clipped, stapled or otherwise attached to any requested document.
9. In the event such file(s) or documents(s) has (have) been removed, either for
the purpose of this action or for some other purpose, please state the name and address of the
person who removed the file, the title of the file and each sub-file, if any, maintained within
the file, and the present location of the file.
10. The words "and" and "or" shall be construed either conjunctively or
disjunctively to bring within the scope of these requests any documents which might
otherwise be construed to be outside their scope.
11. The term ‘invoice’ or ‘statement’ means any invoice, statement, bill, proof of
purchase, receipt, or any other document evidencing a debt or expense incurred by Plaintiff
and/or its agents.
H. INSTRUCTIONS
1. Unless otherwise specified, each production request includes the period of
time from January 2000 through the date that the documents responsive to this request are
produced by Defendant.
2. Each of the following requests is continuing, and in the event that at any later
date you obtain or discover any additional document responsive to any request, you shall
submit such document promptly.
3. If an objection is made to any request herein, all documents covered by the
request not subject to the objection should be produced. Similarly, if an objection is made to
production of a document, the portion(s) of that document not subject to objection should be
produced with the portion(s) objected to deleted and indicated clearly.
4. Each document is to be produced in its entirety even if only a portion of the
document is related to the identified subject matter and without abbreviation, editing, or
expurgation and including all appendices, tables, or other attachments. If an appendix, table,
or other attachment is not presented with the original but is attached to a copy thereof or is
otherwise available, it should be submitted and clearly marked to indicate the document to
which it corresponds. With the exception of privileged material, no document or portion
thereof should be masked or deleted in any manner. To the extent possible, documents
should be produced in the same order and arrangement as in the file form which they are
FC-772068 2 CACEI5012974 (11)taken,
5. Unless otherwise requested, in lieu of producing original documents, you
may produce photocopies, provided that you shall retain the original documents and produce
them to the Plaintiffs upon request. Further, copies of original documents may be submitted
in lieu of originals only if they are true, correct, and complete copies of the original
documents, and their submission constitutes a waiver of any claim as to the authenticity of
the copy should it be necessary to introduce such copy into evidence in any legal
proceeding. Please provide color copies of any document originally produced in color or
containing type, writing, or other marks in any color other than black.
6. Documents that may be responsive to more than one request need not be
submitted more than once; however, such documents should be so identified.
7. AJl headings herein are included only for organization purposes and should
not be construed as being part of any request, or as limiting any request in any manner.
8. When producing the documents, please keep all documents segregated by
the file in which the documents are contained and indicate the name of the file in which the
documents are contained and the name of the documents being produced.
9. When producing the required documents, please produce all other
documents that are clipped, stapled or otherwise attached to any requested document.
10. _ In the event such file(s) or documents(s) has (have) been removed, either for
the purpose of this action or for some other purpose, please state the name and address of the
person who removed the file, the title of the file and each sub-file, if any, maintained within
the file, and the present location of the file.
11. If you choose to withhold from production for inspection and copying on the
ground of privilege or the like, it is requested that you provide the following information:
date, type of document, author, addressee or recipient, present location, custodian, number
of pages, general description, privilege claimed, and any other pertinent information.
TH, PRIVILEGE
If any document would be required to be produced in response to any request except
for the fact that a privilege against production is claimed, set forth for each such document:
1 Its date, title, type of document (memorandum, letter, etc.), and length;
2. Its waiver, preparer, sender, addressee, recipient and copyee;
3. A general description of its subject matter (without revealing the information
as to which privilege is claimed);
4. The exact grounds upon which the objection to production is based;
5. The identity of all persons, in addition to those identified as required by
section 2, supra, known to you who have seen or had access to the document,
6. The identity of the person now in possession of the document.
TV. DOCUMENTS NO LONGER IN EXISTENCE OR NO
LONGER UNDER POSSESSION, CUSTODY OR CONTROL
If any document, requested herein was at one time in existence and under Plaintiff's
possession, custody or control but has been lost, discarded or destroyed or has been removed
from Plaintiff's possession, custody or control, with respect to each such document:
FC-772068 3 CACE1 5012974 (11)1. Identify and describe such document by date, title and type of document;
2. State when each such document was most recently in the possession or
subject to the contro! of Plaintiff and what disposition was made of such document,
including an identification of the person, if any, presently in possession or control of such
document;
3. State when such document was transferred or destroyed, identify the person
who transferred or destroyed such document and the persons who authorized or directed that
the document be transferred or destroyed or having knowledge of its transfer or destruction
and state the reason such document was transferred or destroyed; and
4, Identify all persons having knowledge of the contents thereof.
FC-772068 4 CACE15012974 (11)The following documents are requested to be produced:
1, Please attach a statement that indicates the total amount owed by the
debtor and itemize the amount and basis for the following fees, if applicable:
The past due scheduled principal payments.
The interest due.
The past due taxes.
The hazard insurance due,
The Mortgage insurance premiums.
All late fees.
Any homeowners’ association dues or assessments.
All court filing fees.
All service of process fees.
All postage, UPS or Federal Express fees.
All advertising of any public sale.
All publication expenses.
. All courier fees,
All fax fees.
All property inspection fees.
All property preservation fees.
All broker price opinion (“BPO”) fees.
All legal fees.
All corporate advance fees.
All recoverable corporate advance fees.
All non-recoverable corporate advance fees.
Ail document release fees.
All fees paid to any provider of any type of outsource services, whether or not
the service is related to performing or non-performing Mortgage loans.
All fees paid for the transfer of any documents, data, information, images, or
information to any national, regional or local attorneys.
All bills, statements or invoices received from any attorneys, including all
detailed time and expense records.
z. Any and all other charges and/or fees allegedly incurred for which Plaintiff is
seeking reimbursement from Defendants.
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2. For each charge and/or fee listed on each and every statement provided in
response to Request #1, please produce copies of front and back of all invoices for each
charge stated therein.
3. For each and every document provided in response to Requests #1 and #2,
please provide all documents evidencing your right to seek reimbursement for said
charges and/or fees from Defendants.
4, For each and every document provided in response to Requests #1 and #2,
please provide copies of and/or proof of all checks (front and back), drafts (front and
FC-772068 5 CACE15012974 (11)back), money orders (front and back), wire transfers and all other methods of payment
used to pay invoices for each charge and/or fee.
5. Produce copies of all property inspection reports, appraisals, broker price
opinions (“BPO”) and reports done on Defendants’ property.
6. Produce copies of front and back of all agreements, retainers, contracts
and understandings with vendors that have been paid for any charge identified in Request
#1 from the inception of this account to the present date.
7. A copy of all notices and/or letters mailed in response to the terms
referenced the Mortgage attached to the complaint.
8. A copy of all correspondence, letters, memos, demands, notices, e-mails,
or any other form of written communication sent to Defendant with regards to the subject
loan from the date of application to the present, including but not limited to those sent by
Plaintiff and/or its predecessors in interest, master servicers, sub-servicers, attorneys,
agents or any other person and/or entity working on behalf of Plaintiff.
9. A copy of all proof of mailing of the notice(s), correspondence and or
letter(s) produced in response to Requests #7 and #8, including but not limited to: mail
logs, delivery confirmation, return receipt (USPS green card), tracking numbers, and all
documents evidencing the mailing of the notice.
10. A copy of all notices and/or letters mailed in response to the requirements
set forth in 12 U.S.C. 1701x(c)(5)(A).
11. A copy of all proof of mailing of the notice(s), correspondence and or
letter(s) produced in response to Requests #10, including but not limited to: mail logs,
delivery confirmation, return receipt (USPS green card), tracking numbers, and all
documents evidencing the mailing of the notice.
12. All documents that evidence compliance with the requirements set forth in
12 U.S.C. 1701x(c)(5)(A).
13. All documents that show the exact date that Plaintiff came into possession
of the original subject Promissory Note, including but not limited to transmittal letters,
receipts, screen shots, memoranda, correspondence, and referrals.
14. Accopy of the complete loan payment history.
15. All documents that show the exact date that any indorsement(s) and/or
allonge(s) were placed or attached to the original subject Promissory Note, including but
not limited to transmittal letters, receipts, screen shots, memoranda, correspondence, and
referrals.
FC-772068 6 CACE15012974 (11)16. All documents in Plaintiffs possession or available to Plaintiff that
establish that the Plaintiff is the legal, beneficial or equitable owner or holder of the
subject promissory Note.
17. The original subject Promissory Note. A copy of the front and back of all
pages of the original subject Promissory Note and any attachments thereto may be
provided in licu of the original. Defendants reserve the right to inspect the original
Promissory Note at a date and time to be coordinated by the parties.
18. All documents in Plaintiff's possession or available to Plaintiff that
identify what entity is the owner or holder of the subject promissory Note.
19. Produce copies of front/back of all assignments, transfers, allonges, or
other documents evidencing a transfer, sale or assignment of the subject Promissory Note
from the inception of this account to the present date.
20. Produce copies of front/back of all assignments, transfers, allonges, or
other documents evidencing a transfer, sale or assignment of the subject Mortgage from
the inception of this account to the present date including but not limited to any such
assignment on the Mortgage Electronic Registration System (“MERS”)
21. Copies of any communication(s), notice(s), record(s), note(s), retainer(s),
referral(s) to proceed with foreclosure, internal memoranda, or other documents relating
to the filing of this foreclosure action by the Plaintiff.
22. All documents that purport to grant authority to any person who signed
each indorsement(s), allonge(s), and/or assignment(s) of the subject Promissory Note
and/or subject mortgage.
23. A copy of the notice sent to Defendants pursuant to Section 131(g) of the
Truth in Lending Act (15 USC § 1641) that includes:
a. The assignee's identity, address and phone number;
b. The date of transfer;
¢. Contact information for an agent or party having authority to act on behalf
of the assignee
d. The location of the place where transfer of ownership of the debt is
recorded; and
e. Any other relevant information regarding the assignee.
24. A copy of any agreement(s) between Defendants and any other entity(ies)
that modifies in any way the original terms of the subject Mortgage and/or Promissory
Note.
25. Acomplete copy of the “origination file” for the subject loan.
26. Any document not previously requested that transfers any interest in the
subject loan from original lender including any successor in interest to any other entity.
FC-772068 7 CACE15012974 (11)CERTIFICATE OF SERVICE
¢
I HEREBY CERTIFY that on November 24, 2015, a true and correct copy of
the foregoing was forwarded electronic mail (servicemail@aldridgepite.com, DEF
AMTRUST BANK: notice@kahaneandassociates.com) to: Gweneth M. Brimm, Esq.,
Aldridge Pite, LLP, 1615 South Congress Avenue, Delray Beach, Florida 33445. Fax:
(561)392-6965.
LOAN LAWYERS, LLC
Attorneys for Defendants
2150 S. Andrews Ave, 2™ Floor
Fort Lauderdale, FL 33316
Telephone: (954) 523-4357
Faésinile: (954) 581-2786
FBN‘059025
SONJA-LUCIENNE CAJUSTE, ESQ.
FBN 102983
MICHAEL A. CITRON, ESQ.
FBN 105083
MATIS H. ABARBANEL, ESQ.
FBN 130435
MATTHEW D. BAVARO ESQ.
FBN 175821
FC-772068 8 CACE15012974 (1)
Preview
Filing # 34849299 E-Filed 11/24/2015 03:58:04 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE!5012974 (11) WELLS FARGO BANK, NA, Plaintiff, VS. GEORGE T. GOODMAN AND IRMA OLIVARES, et. al. Defendants. i DEFENDANTS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS COME NOW the Defendants, GEORGE T. GOODMAN AND IRMA OLIVARES, by and through undersigned counsel, and pursuant to Florida Rules of Civil Procedure 1.350, and request Plaintiff, WELLS FARGO BANK, NA, to produce for inspection and copying at the offices of the undersigned attorney the documents set forth below on or before the thirtieth (30th) day after service of this Request For Production of Documents. I. DEFINITIONS 1. The term "you" or "your" means the party or parties to which this request is addressed, including attorneys and all other persons acting or purporting to act on behalf of the party or parties. 2. The term "person" means any natural person, individual, proprictorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons, or other entity. 3. The term “document” means any written or graphic matter and other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and_all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including bat not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, inter-office and intra-office telephone calls, diaries, chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, charts, ledgers, invoices, worksheets, receipts, retums, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases, graphic or aural records or representations of any kind ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/24/2015 3:58:04 PM.****(including without limitation, photographs, microfiche, microfilm, videotape, records and motion pictures) and electronic, mechanical or electric records or representations of any kind (including without limitation, tapes, cassettes, discs and records). 4. The term “all documents” means every document or group or documents as above defined that are known to you or that can be located or discovered by reasonably diligent efforts. 5. The term “communication(s)” means every manner or means of disclosure, transfer or exchange of information, whether in person, by telephone, mail, personal delivery or otherwise. 6. As used herein, the singuiar shall include the plural, the plural shall include the singular, and the masculine, feminine and neither shall include each of the genders. 7. When producing the documents, please keep all documents segregated by the file in which the documents are contained and indicate the name of the file in which the documents are contained and the name of the documents being produced. 8. When producing the required documents, please produce all other documents that are clipped, stapled or otherwise attached to any requested document. 9. In the event such file(s) or documents(s) has (have) been removed, either for the purpose of this action or for some other purpose, please state the name and address of the person who removed the file, the title of the file and each sub-file, if any, maintained within the file, and the present location of the file. 10. The words "and" and "or" shall be construed either conjunctively or disjunctively to bring within the scope of these requests any documents which might otherwise be construed to be outside their scope. 11. The term ‘invoice’ or ‘statement’ means any invoice, statement, bill, proof of purchase, receipt, or any other document evidencing a debt or expense incurred by Plaintiff and/or its agents. H. INSTRUCTIONS 1. Unless otherwise specified, each production request includes the period of time from January 2000 through the date that the documents responsive to this request are produced by Defendant. 2. Each of the following requests is continuing, and in the event that at any later date you obtain or discover any additional document responsive to any request, you shall submit such document promptly. 3. If an objection is made to any request herein, all documents covered by the request not subject to the objection should be produced. Similarly, if an objection is made to production of a document, the portion(s) of that document not subject to objection should be produced with the portion(s) objected to deleted and indicated clearly. 4. Each document is to be produced in its entirety even if only a portion of the document is related to the identified subject matter and without abbreviation, editing, or expurgation and including all appendices, tables, or other attachments. If an appendix, table, or other attachment is not presented with the original but is attached to a copy thereof or is otherwise available, it should be submitted and clearly marked to indicate the document to which it corresponds. With the exception of privileged material, no document or portion thereof should be masked or deleted in any manner. To the extent possible, documents should be produced in the same order and arrangement as in the file form which they are FC-772068 2 CACEI5012974 (11)taken, 5. Unless otherwise requested, in lieu of producing original documents, you may produce photocopies, provided that you shall retain the original documents and produce them to the Plaintiffs upon request. Further, copies of original documents may be submitted in lieu of originals only if they are true, correct, and complete copies of the original documents, and their submission constitutes a waiver of any claim as to the authenticity of the copy should it be necessary to introduce such copy into evidence in any legal proceeding. Please provide color copies of any document originally produced in color or containing type, writing, or other marks in any color other than black. 6. Documents that may be responsive to more than one request need not be submitted more than once; however, such documents should be so identified. 7. AJl headings herein are included only for organization purposes and should not be construed as being part of any request, or as limiting any request in any manner. 8. When producing the documents, please keep all documents segregated by the file in which the documents are contained and indicate the name of the file in which the documents are contained and the name of the documents being produced. 9. When producing the required documents, please produce all other documents that are clipped, stapled or otherwise attached to any requested document. 10. _ In the event such file(s) or documents(s) has (have) been removed, either for the purpose of this action or for some other purpose, please state the name and address of the person who removed the file, the title of the file and each sub-file, if any, maintained within the file, and the present location of the file. 11. If you choose to withhold from production for inspection and copying on the ground of privilege or the like, it is requested that you provide the following information: date, type of document, author, addressee or recipient, present location, custodian, number of pages, general description, privilege claimed, and any other pertinent information. TH, PRIVILEGE If any document would be required to be produced in response to any request except for the fact that a privilege against production is claimed, set forth for each such document: 1 Its date, title, type of document (memorandum, letter, etc.), and length; 2. Its waiver, preparer, sender, addressee, recipient and copyee; 3. A general description of its subject matter (without revealing the information as to which privilege is claimed); 4. The exact grounds upon which the objection to production is based; 5. The identity of all persons, in addition to those identified as required by section 2, supra, known to you who have seen or had access to the document, 6. The identity of the person now in possession of the document. TV. DOCUMENTS NO LONGER IN EXISTENCE OR NO LONGER UNDER POSSESSION, CUSTODY OR CONTROL If any document, requested herein was at one time in existence and under Plaintiff's possession, custody or control but has been lost, discarded or destroyed or has been removed from Plaintiff's possession, custody or control, with respect to each such document: FC-772068 3 CACE1 5012974 (11)1. Identify and describe such document by date, title and type of document; 2. State when each such document was most recently in the possession or subject to the contro! of Plaintiff and what disposition was made of such document, including an identification of the person, if any, presently in possession or control of such document; 3. State when such document was transferred or destroyed, identify the person who transferred or destroyed such document and the persons who authorized or directed that the document be transferred or destroyed or having knowledge of its transfer or destruction and state the reason such document was transferred or destroyed; and 4, Identify all persons having knowledge of the contents thereof. FC-772068 4 CACE15012974 (11)The following documents are requested to be produced: 1, Please attach a statement that indicates the total amount owed by the debtor and itemize the amount and basis for the following fees, if applicable: The past due scheduled principal payments. The interest due. The past due taxes. The hazard insurance due, The Mortgage insurance premiums. All late fees. Any homeowners’ association dues or assessments. All court filing fees. All service of process fees. All postage, UPS or Federal Express fees. All advertising of any public sale. All publication expenses. . All courier fees, All fax fees. All property inspection fees. All property preservation fees. All broker price opinion (“BPO”) fees. All legal fees. All corporate advance fees. All recoverable corporate advance fees. All non-recoverable corporate advance fees. Ail document release fees. All fees paid to any provider of any type of outsource services, whether or not the service is related to performing or non-performing Mortgage loans. All fees paid for the transfer of any documents, data, information, images, or information to any national, regional or local attorneys. All bills, statements or invoices received from any attorneys, including all detailed time and expense records. z. Any and all other charges and/or fees allegedly incurred for which Plaintiff is seeking reimbursement from Defendants. as er7ey 2 epoB RT RT rams Aan oP x < 2. For each charge and/or fee listed on each and every statement provided in response to Request #1, please produce copies of front and back of all invoices for each charge stated therein. 3. For each and every document provided in response to Requests #1 and #2, please provide all documents evidencing your right to seek reimbursement for said charges and/or fees from Defendants. 4, For each and every document provided in response to Requests #1 and #2, please provide copies of and/or proof of all checks (front and back), drafts (front and FC-772068 5 CACE15012974 (11)back), money orders (front and back), wire transfers and all other methods of payment used to pay invoices for each charge and/or fee. 5. Produce copies of all property inspection reports, appraisals, broker price opinions (“BPO”) and reports done on Defendants’ property. 6. Produce copies of front and back of all agreements, retainers, contracts and understandings with vendors that have been paid for any charge identified in Request #1 from the inception of this account to the present date. 7. A copy of all notices and/or letters mailed in response to the terms referenced the Mortgage attached to the complaint. 8. A copy of all correspondence, letters, memos, demands, notices, e-mails, or any other form of written communication sent to Defendant with regards to the subject loan from the date of application to the present, including but not limited to those sent by Plaintiff and/or its predecessors in interest, master servicers, sub-servicers, attorneys, agents or any other person and/or entity working on behalf of Plaintiff. 9. A copy of all proof of mailing of the notice(s), correspondence and or letter(s) produced in response to Requests #7 and #8, including but not limited to: mail logs, delivery confirmation, return receipt (USPS green card), tracking numbers, and all documents evidencing the mailing of the notice. 10. A copy of all notices and/or letters mailed in response to the requirements set forth in 12 U.S.C. 1701x(c)(5)(A). 11. A copy of all proof of mailing of the notice(s), correspondence and or letter(s) produced in response to Requests #10, including but not limited to: mail logs, delivery confirmation, return receipt (USPS green card), tracking numbers, and all documents evidencing the mailing of the notice. 12. All documents that evidence compliance with the requirements set forth in 12 U.S.C. 1701x(c)(5)(A). 13. All documents that show the exact date that Plaintiff came into possession of the original subject Promissory Note, including but not limited to transmittal letters, receipts, screen shots, memoranda, correspondence, and referrals. 14. Accopy of the complete loan payment history. 15. All documents that show the exact date that any indorsement(s) and/or allonge(s) were placed or attached to the original subject Promissory Note, including but not limited to transmittal letters, receipts, screen shots, memoranda, correspondence, and referrals. FC-772068 6 CACE15012974 (11)16. All documents in Plaintiffs possession or available to Plaintiff that establish that the Plaintiff is the legal, beneficial or equitable owner or holder of the subject promissory Note. 17. The original subject Promissory Note. A copy of the front and back of all pages of the original subject Promissory Note and any attachments thereto may be provided in licu of the original. Defendants reserve the right to inspect the original Promissory Note at a date and time to be coordinated by the parties. 18. All documents in Plaintiff's possession or available to Plaintiff that identify what entity is the owner or holder of the subject promissory Note. 19. Produce copies of front/back of all assignments, transfers, allonges, or other documents evidencing a transfer, sale or assignment of the subject Promissory Note from the inception of this account to the present date. 20. Produce copies of front/back of all assignments, transfers, allonges, or other documents evidencing a transfer, sale or assignment of the subject Mortgage from the inception of this account to the present date including but not limited to any such assignment on the Mortgage Electronic Registration System (“MERS”) 21. Copies of any communication(s), notice(s), record(s), note(s), retainer(s), referral(s) to proceed with foreclosure, internal memoranda, or other documents relating to the filing of this foreclosure action by the Plaintiff. 22. All documents that purport to grant authority to any person who signed each indorsement(s), allonge(s), and/or assignment(s) of the subject Promissory Note and/or subject mortgage. 23. A copy of the notice sent to Defendants pursuant to Section 131(g) of the Truth in Lending Act (15 USC § 1641) that includes: a. The assignee's identity, address and phone number; b. The date of transfer; ¢. Contact information for an agent or party having authority to act on behalf of the assignee d. The location of the place where transfer of ownership of the debt is recorded; and e. Any other relevant information regarding the assignee. 24. A copy of any agreement(s) between Defendants and any other entity(ies) that modifies in any way the original terms of the subject Mortgage and/or Promissory Note. 25. Acomplete copy of the “origination file” for the subject loan. 26. Any document not previously requested that transfers any interest in the subject loan from original lender including any successor in interest to any other entity. FC-772068 7 CACE15012974 (11)CERTIFICATE OF SERVICE ¢ I HEREBY CERTIFY that on November 24, 2015, a true and correct copy of the foregoing was forwarded electronic mail (servicemail@aldridgepite.com, DEF AMTRUST BANK: notice@kahaneandassociates.com) to: Gweneth M. Brimm, Esq., Aldridge Pite, LLP, 1615 South Congress Avenue, Delray Beach, Florida 33445. Fax: (561)392-6965. LOAN LAWYERS, LLC Attorneys for Defendants 2150 S. Andrews Ave, 2™ Floor Fort Lauderdale, FL 33316 Telephone: (954) 523-4357 Faésinile: (954) 581-2786 FBN‘059025 SONJA-LUCIENNE CAJUSTE, ESQ. FBN 102983 MICHAEL A. CITRON, ESQ. FBN 105083 MATIS H. ABARBANEL, ESQ. FBN 130435 MATTHEW D. BAVARO ESQ. FBN 175821 FC-772068 8 CACE15012974 (1)