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 # 117475123 E-Filed 12/01/2020 05:03:52 PM
IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT OF
THE STATE OF FLORIDA, IN AND FOR WASHINGTON COUNTY
THE BANK OF NEW YORK MELLON f/k/a
THE BANK OF NEW YORK as Trustee for
Nationstar Home Equity Loan Trust 2007-A
Plaintiff,
vs. CASE NO. 19-4414CA
VICKIE ALEXANDRA LARGE
a/k/a VICKIE LARGE, et al.,
DEFENDANTS.
REQUEST FOR PRODUCTION
COMES NOW the Defendant, Vickie Alexandra Large a/k/a Vickie Large, by and
through her undersigned counsel, and requests Plaintiff, ARCPE Holdings, LLC, its
agents, representatives, and attorneys produce the following documents for inspection
and copying at the Law Offices of Mitch Dever located at 400 Thomas Drive a/k/a 7106
Quail Hollow Drive in Panama City Beach, Florida 32408, within thirty (30) days of service
hereof.
REQUEST TO PRODUCE
1. Copies of all Loan Documents, front and back.
2. Copies of all payments to any third-parties made on behaif of the Defendant.
3. 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.
4. Copies of any and all documents, materials, and/or correspondenceevidencing 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.
5. Copies of any and all documents you intend to use or introduce at any
hearing or trial in this case.
6. 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.
7. A complete payment history, including a breakdown of the application of all
funds to the Defendant's account.
8. Copies of all property inspection reports, appraisals, BPOs and reports done
on the subject property.
PLEASE NOTE: YOU MAY COMPLY WITH THIS REQUEST BY COPYING THE
REQUESTED DOCUMENTS AND MAILING THEM TO THE UNDERSIGNED
ATTORNEY WITH A BILL FOR REASONABLE COPYING COSTS. PLEASE
CONTACT THE UNDERSIGNED BEFORE COPYING THE DOCUMENTS TO ADVISE
AS TO THE APPROXIMATE NUMBER OF DOCUMENTS WHICH FALL WITHIN THE
SCOPE OF THIS REQUEST.
Dated this L day of
Mitch Dever, Esquira, ~~
Florida Bar No. 0939730
P.O. Box 9811
Panama City Beach, FL 32417
Telephone: (850) 234-5555
Fax: (850) 234-7677
Email: mitchdever@comcast.net
Attorney for Vickie LargeCERTIFICATE OF SERVICE
| hereby certify that a copy of the above and foregoing has been sent by E-Portal to
Summer Hodges, Attorney for Plaintiff at suhodges@logs.com, this _/ day of
December, 2020.
poem
‘i —
Mitch Dever, Eau
Document Filed Date
December 01, 2020
Case Filing Date
December 04, 2019
Category
Real Prop/Mort Foreclosure-Non-Homestead, Residential $50-249K
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Filing # 117475123 E-Filed 12/01/2020 05:03:52 PM IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR WASHINGTON COUNTY THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK as Trustee for Nationstar Home Equity Loan Trust 2007-A Plaintiff, vs. CASE NO. 19-4414CA VICKIE ALEXANDRA LARGE a/k/a VICKIE LARGE, et al., DEFENDANTS. REQUEST FOR PRODUCTION COMES NOW the Defendant, Vickie Alexandra Large a/k/a Vickie Large, by and through her undersigned counsel, and requests Plaintiff, ARCPE Holdings, LLC, its agents, representatives, and attorneys produce the following documents for inspection and copying at the Law Offices of Mitch Dever located at 400 Thomas Drive a/k/a 7106 Quail Hollow Drive in Panama City Beach, Florida 32408, within thirty (30) days of service hereof. REQUEST TO PRODUCE 1. Copies of all Loan Documents, front and back. 2. Copies of all payments to any third-parties made on behaif of the Defendant. 3. 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. 4. Copies of any and all documents, materials, and/or correspondenceevidencing 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. 5. Copies of any and all documents you intend to use or introduce at any hearing or trial in this case. 6. 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. 7. A complete payment history, including a breakdown of the application of all funds to the Defendant's account. 8. Copies of all property inspection reports, appraisals, BPOs and reports done on the subject property. PLEASE NOTE: YOU MAY COMPLY WITH THIS REQUEST BY COPYING THE REQUESTED DOCUMENTS AND MAILING THEM TO THE UNDERSIGNED ATTORNEY WITH A BILL FOR REASONABLE COPYING COSTS. PLEASE CONTACT THE UNDERSIGNED BEFORE COPYING THE DOCUMENTS TO ADVISE AS TO THE APPROXIMATE NUMBER OF DOCUMENTS WHICH FALL WITHIN THE SCOPE OF THIS REQUEST. Dated this L day of Mitch Dever, Esquira, ~~ Florida Bar No. 0939730 P.O. Box 9811 Panama City Beach, FL 32417 Telephone: (850) 234-5555 Fax: (850) 234-7677 Email: mitchdever@comcast.net Attorney for Vickie LargeCERTIFICATE OF SERVICE | hereby certify that a copy of the above and foregoing has been sent by E-Portal to Summer Hodges, Attorney for Plaintiff at suhodges@logs.com, this _/ day of December, 2020. poem ‘i — Mitch Dever, Eau