On December 04, 2019 a
Party Discovery
was filed
involving a dispute between
Bank Of New York Mellon,
and
Large, Shawn Michael,
Large, Vickie Alexandra,
Unknown Parties In Possession 1,
Unknown Parties In Possession 2,
Unknown Spouse Of Vickie Alexandra Large,
for Real Prop/Mort Foreclosure-Non-Homestead, Residential $50-249K
in the District Court of Bay County.
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Filing # 121218682 E-Filed 02/11/2021 10:43:40 AM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
CIVIL DIVISION
| THE BANK OF NEW YORK MELLON f/k/a Case #: 19004414CA
THE BANK OF NEW YORK as Trustee for
Nationstar Home Equity Loan Trust 2007-A
Plaintiff,
“VS.-
Vickie Alexandra Large a/k/a Victoria
Alexandra Large a/k/a Vickie Large; et al.
Defendant(s).
PLAINTIFF’S RESPONSE AND OBJECTIONS FOR PRODUCTION
TO DEFENDANTS’ FIRST REQUEST
Plaintiff, THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW
YORK as Trustee for Nationstar Home Equity Loan Trust 2007-A, by and through its
undersigned counsel, hereby files these Responses and Objections to Defendant, Vickie
Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large’s, First Request for
Production dated December 1, 2020, and states as follows:
1. Request: Copies of all Loan Documents, front and back.
Answer: Attached hereto is a copy of the Note, Mortgage and Loan
Modification.
2. Request: Copies of all payments to any third-parties made on behalf of the
Defendant.
Answer:
loan.
Attached hereto is a copy of the Payment History for the subject
3. Request: Copies of all documents you mailed to the Defendant prior to filing of
this lawsuit, including, but not limited to, any and all notices as required under the loan
documents, as well as any and all statutory mandated notices,
Answer: Attached hereto is a copy of the Demand Letter for the subject loan.
The Plaintiff objects to providing any additional documents, as the
documents requested are irrelevant and not likely to lead to the discovery of
admissible evidence.
i
4. Request: Copies of all documents, materials, and/or correspondence evidencing
Defendant's past due property taxes, including, but not limited to bills. statements, and/or
invoices from the date of inception of the loan to the date of filing this lawsuit.
Answer: Attached hereto is a copy of the Payment History for the subject
Joan. The Plaintiff objects to providing any additional documents, as the
documents requested are irrelevant and not likely to lead to the discovery of
admissible evidence.
5. Request:
hearing or trial in this case.
Copies of any and all documents you intend to use or introduce at any
Answer: Undetermined at this time. However, at a minimum, see attached
copy of the Note, Mortgage, Demand Letter and Payment History for this
Joan. The Plaintiff reserves the right to add any additional documents not yet
contemplated at this time.
6. Request: A complete loan history for the Mortgage. including, but not limited to.
any and all transactions of any nature with respect to the Mortgage, as well as all transaction
codes associated with every entry and the plain English definitions for each such transaction
code.
Answer:
loan.
Attached hereto is a copy of the Payment History for the subject
7. Request: A complete payment
of all funds to the Defendant's account.
history. including a breakdown of the application
Answer:
loan.
Attached hereto is a copy of the Payment History for the subject
8. Request: Copies of all property inspection reports, appraisals. BPOs and reports
done on the subject property.
Answer: Objection. The documents requested are irrelevant and not likely to
lead to the discovery of admissible evidence.
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing has been furnished
by U.S. Mail and/or email service ifan email address is so listed below onthis i day of
Gh ,2021 to the following:
Shawn Michael Large, 3426 Douglas Road, Apartment B, Panama City, FL 32405
Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large, c/o Mitch Dever,
Esq., mitchdever@comcast.net
*Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiff’s counsel
hereby designates its primary email address for the purposes of
email service as: FLeService@logs.com*
LOGS LEGAL GROUP LLP
Attomeys for Plaintiff
4630 Woodland Corporate Blvd., Suite 100
Tampa, Florida 33614
Telephone: (813) 880-8888 Ext. 55153
Fax: (813) 880-8800
For Email Service Only: FLeService@logs.com
For all other inquiries: jkopf@logs.com
By: /s/ Jennifer Kopf.
Jennifer Kopf, Esq.
FL Bar # 50949
Pursuant to the Fair Debt Collections Practices Act, you are advised that this office may be
deemed a debt collector and any information obtained may be used for that purpose.
19-321900 FCO] CXE
3
Document Filed Date
February 11, 2021
Case Filing Date
December 04, 2019
Category
Real Prop/Mort Foreclosure-Non-Homestead, Residential $50-249K
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Filing # 121218682 E-Filed 02/11/2021 10:43:40 AM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CIVIL DIVISION | THE BANK OF NEW YORK MELLON f/k/a Case #: 19004414CA THE BANK OF NEW YORK as Trustee for Nationstar Home Equity Loan Trust 2007-A Plaintiff, “VS.- Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large; et al. Defendant(s). PLAINTIFF’S RESPONSE AND OBJECTIONS FOR PRODUCTION TO DEFENDANTS’ FIRST REQUEST Plaintiff, THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK as Trustee for Nationstar Home Equity Loan Trust 2007-A, by and through its undersigned counsel, hereby files these Responses and Objections to Defendant, Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large’s, First Request for Production dated December 1, 2020, and states as follows: 1. Request: Copies of all Loan Documents, front and back. Answer: Attached hereto is a copy of the Note, Mortgage and Loan Modification. 2. Request: Copies of all payments to any third-parties made on behalf of the Defendant. Answer: loan. Attached hereto is a copy of the Payment History for the subject 3. Request: Copies of all documents you mailed to the Defendant prior to filing of this lawsuit, including, but not limited to, any and all notices as required under the loan documents, as well as any and all statutory mandated notices, Answer: Attached hereto is a copy of the Demand Letter for the subject loan. The Plaintiff objects to providing any additional documents, as the documents requested are irrelevant and not likely to lead to the discovery of admissible evidence. i 4. Request: Copies of all documents, materials, and/or correspondence evidencing Defendant's past due property taxes, including, but not limited to bills. statements, and/or invoices from the date of inception of the loan to the date of filing this lawsuit. Answer: Attached hereto is a copy of the Payment History for the subject Joan. The Plaintiff objects to providing any additional documents, as the documents requested are irrelevant and not likely to lead to the discovery of admissible evidence. 5. Request: hearing or trial in this case. Copies of any and all documents you intend to use or introduce at any Answer: Undetermined at this time. However, at a minimum, see attached copy of the Note, Mortgage, Demand Letter and Payment History for this Joan. The Plaintiff reserves the right to add any additional documents not yet contemplated at this time. 6. Request: A complete loan history for the Mortgage. including, but not limited to. any and all transactions of any nature with respect to the Mortgage, as well as all transaction codes associated with every entry and the plain English definitions for each such transaction code. Answer: loan. Attached hereto is a copy of the Payment History for the subject 7. Request: A complete payment of all funds to the Defendant's account. history. including a breakdown of the application Answer: loan. Attached hereto is a copy of the Payment History for the subject 8. Request: Copies of all property inspection reports, appraisals. BPOs and reports done on the subject property. Answer: Objection. The documents requested are irrelevant and not likely to lead to the discovery of admissible evidence. 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy ofthe foregoing has been furnished by U.S. Mail and/or email service ifan email address is so listed below onthis i day of Gh ,2021 to the following: Shawn Michael Large, 3426 Douglas Road, Apartment B, Panama City, FL 32405 Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large, c/o Mitch Dever, Esq., mitchdever@comcast.net *Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiff’s counsel hereby designates its primary email address for the purposes of email service as: FLeService@logs.com* LOGS LEGAL GROUP LLP Attomeys for Plaintiff 4630 Woodland Corporate Blvd., Suite 100 Tampa, Florida 33614 Telephone: (813) 880-8888 Ext. 55153 Fax: (813) 880-8800 For Email Service Only: FLeService@logs.com For all other inquiries: jkopf@logs.com By: /s/ Jennifer Kopf. Jennifer Kopf, Esq. FL Bar # 50949 Pursuant to the Fair Debt Collections Practices Act, you are advised that this office may be deemed a debt collector and any information obtained may be used for that purpose. 19-321900 FCO] CXE 3