On April 09, 2008 a
Motion-Secondary
was filed
involving a dispute between
Deutsche Bank National Trust Company As Trustee,
Deutsche Bank N T Company As Indenture Trustee,
and
for Circuit Civil
in the District Court of St. Lucie County.
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IN THE CIRCUIT COURT OF THE 19th JUDICIAL CIRCUIT
-OF FLORIDA; IN AND FOR SAINT LUCIE COUNTY
Deutsche Bank Trust Company Americas
formerly known as Banker's Trust Company,
as Trustee and Custodian
Case #: 2008 CA 003079
Plaintiff, Division #:
“VS UNC:
Jerome B. Perlmutter, an Unremarried
Widower and Surviving Spouse of Kathleen
S. Perlmutter (DOD 02/14/2008), Deceased;
Unknown Parties in Possession #1; Unknown
Parties in Possession #2; If living, and all ;
Unknown Parties claiming by, through, under :
and against the above named Defendant(s) .
who are not known to be dead or alive,
whether said Unknown Parties may claim an
interest as Spouse, Heirs, Devisees, Grantees,
or Other Claimants
Defendant(s).
PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION
Plaintiff, Deutsche Bank Trust Company Americas formerly known as Banker's Trust
Company, as Trustee and Custodian, by and through its undersigned counsel, hereby responds to
Defendant(s), Jerome B. Perlmutter, an Unremarried Widower and Surviving Spouse of Kathleen
S. Perlmutter (DOD 02/14/2008), Deceased, pursuant to Fla.R.Civ.P. 1.350 and sets forth as
follows:
1. Plaintiff objects to this request on the grounds that it is overly broad and unduly
burdensome. Further to and without waiving its foregoing objections Plaintiff responds that it
has produced a copy of the loan payment history and correspondence related to payments on the
subject loan, which are attached hereto as Exhibit “A”.
2. Plaintiff responds that the loan closing file is produced as Exhibit “B” hereto.”
th
3. Plaintiff responds that a true and accurate copy of the original mortgage is produced as
Exhibit “C” hereto.
4. Plaintiff responds that a true and accurate copy of the original assignment of mortgage
is produced as Exhibit “D” hereto.
"THIS COMMUNICATION, FROM A DEBT COLLECTOR, IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE."
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
U.S. Mail on this_ 10 day of Feb + , 2009, to the following:
Jerome B. Perlmutter, an Unremarried Widower and Surviving Spouse of Kathleen S. Perlmutter
(DOD 02/14/2008), Deceased, c/o Edward W. Becht, Esquire, Post Office Box 2746, Fort Pierce,
FL 34954
Unknown Parties in Possession #1 n/k/a Justine Toombs, 2805 North A1A, Unit G, Fort Pierce,
FL 34949
Unknown Parties in Possession #2 n/k/a Christine Lynch, 2805 North A1A, Unit G, Fort Pierce,
FL 34949
SHAPIRO & FISHMAN, LLP
Attorneys for Plaintiff
2424 North Federal Highway, Suite 360
Boca Raton, Florida 33431
Telephone: (561) 998-6700
Fax: (561) 998-6707
08-095892
Document Filed Date
October 26, 2009
Case Filing Date
April 09, 2008
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IN THE CIRCUIT COURT OF THE 19th JUDICIAL CIRCUIT -OF FLORIDA; IN AND FOR SAINT LUCIE COUNTY Deutsche Bank Trust Company Americas formerly known as Banker's Trust Company, as Trustee and Custodian Case #: 2008 CA 003079 Plaintiff, Division #: “VS UNC: Jerome B. Perlmutter, an Unremarried Widower and Surviving Spouse of Kathleen S. Perlmutter (DOD 02/14/2008), Deceased; Unknown Parties in Possession #1; Unknown Parties in Possession #2; If living, and all ; Unknown Parties claiming by, through, under : and against the above named Defendant(s) . who are not known to be dead or alive, whether said Unknown Parties may claim an interest as Spouse, Heirs, Devisees, Grantees, or Other Claimants Defendant(s). PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION Plaintiff, Deutsche Bank Trust Company Americas formerly known as Banker's Trust Company, as Trustee and Custodian, by and through its undersigned counsel, hereby responds to Defendant(s), Jerome B. Perlmutter, an Unremarried Widower and Surviving Spouse of Kathleen S. Perlmutter (DOD 02/14/2008), Deceased, pursuant to Fla.R.Civ.P. 1.350 and sets forth as follows: 1. Plaintiff objects to this request on the grounds that it is overly broad and unduly burdensome. Further to and without waiving its foregoing objections Plaintiff responds that it has produced a copy of the loan payment history and correspondence related to payments on the subject loan, which are attached hereto as Exhibit “A”. 2. Plaintiff responds that the loan closing file is produced as Exhibit “B” hereto.” th 3. Plaintiff responds that a true and accurate copy of the original mortgage is produced as Exhibit “C” hereto. 4. Plaintiff responds that a true and accurate copy of the original assignment of mortgage is produced as Exhibit “D” hereto. "THIS COMMUNICATION, FROM A DEBT COLLECTOR, IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE." CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail on this_ 10 day of Feb + , 2009, to the following: Jerome B. Perlmutter, an Unremarried Widower and Surviving Spouse of Kathleen S. Perlmutter (DOD 02/14/2008), Deceased, c/o Edward W. Becht, Esquire, Post Office Box 2746, Fort Pierce, FL 34954 Unknown Parties in Possession #1 n/k/a Justine Toombs, 2805 North A1A, Unit G, Fort Pierce, FL 34949 Unknown Parties in Possession #2 n/k/a Christine Lynch, 2805 North A1A, Unit G, Fort Pierce, FL 34949 SHAPIRO & FISHMAN, LLP Attorneys for Plaintiff 2424 North Federal Highway, Suite 360 Boca Raton, Florida 33431 Telephone: (561) 998-6700 Fax: (561) 998-6707 08-095892