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Filing # 116722161 E-Filed 11/16/2020 02:16:46 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR
OSCEOLA COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 2018-CA-003041-MF
HOMEBRIDGE FINANCIAL SERVICES,
INC.,
Plaintiff,
vs.
MICHAEL R. PARKEY AND MARK D.
PARKEY, et. al.,
Defendant(s).
/
PLAINTIFF'S FIRST REQUEST FOR.
PRODUCTION OF DOCUMENTS TO DEFENDANT
PLAINTIFF, NEWREZ LLC D/B/A SHELLPOINT MORTGAGE SERVICING, by and
through the undersigned attorney, pursuant to Florida Rule of Civil Procedure 1.350, serves the
following First Request for Production of Documents to Defendant, MARK D. PARKEY, and
requests within thirty (30) days hereof the production for inspection and copying at the offices of
Robertson, Anschutz & Schneid, P.L., 6409 Congress Avenue, Suite 100, or such alternative
location as the parties may agree, the documents designated below that are in their possession,
custody, or control, as well as written responses to these requests.
I. DEFINITIONS
For purposes of this Request for Production of Documents, the following definitions and instructions apply
and are incorporated into each Request as though fully stated therein:
1. "Loan" means the loan at issue in this action memorialized by that certain promissory note described
below.
2. “Note” means that certain promissory note executed by Defendant(s) Borrower(s) which is at issue and
the subject of this action.
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PAGE 13. “Mortgage” means that certain mortgage, which is at issue in this action, executed by Defendant(s)
Borrower(s) to secure the Loan and/or Note.
4. "Property" refers to the property secured by the Mortgage, and defined specifically in the Mortgage
attached to Plaintiff's complaint subject to Plaintiff's foreclosure in the above-captioned case.
5. “Borrower(s)” means the person(s) who executed the Note and Mortgage listed above.
6. “Original Lender” means the lender listed on the Note.
7. “Lawsuit" means the action initiated by Plaintiff against you by filing the complaint.
8. "Persons" refers to and includes a corporation, partnership, joint venture, proprietorship, firm,
company, unincorporated association, individual, association of individuals, or any other such entity.
9. "Individual" means a natural person.
10. "You" (including "your" and "yours") and “Defendant(s)” shall refer to Defendant(s) Borrower(s)
named above in the case style of this action, and any consultants, attorneys, experts, investigators,
agents or other persons acting on your behalf.
11. "Plaintiff" means Plaintiff named above in the case style of this action, its counsel, and any of its
officers, directors, affiliates, shareholders, attorneys, consultants, experts, investigators, agents or other
persons acting on its behalf, including any current and prior loan servicers.
12. The term "document" has the broadest meaning accorded to it and includes without limitation all
written, typed, printed, reproduced, filmed, electronically or computer-stored, or recorded material or
information of any kind, in the possession, custody, or control of you or any of your past or present
agents, employees, consultants, attorneys or other persons acting on your behalf, including but not
limited to any of the following: correspondence; letters; memoranda; interoffice memoranda; writings;
notes; notebooks; maps; sketches; charts; films and microfilm; studies; plans; analyses; work papers;
statistical records; bills and other billing records; receipts; books; press releases; reports; contracts and
agreements; records; summaries; memorials; minutes; agendas or notes of meetings; conferences;
telephone calls or other conversations; calendars and diaries; appointment books and message pads;
photographs; tape recordings or other audio or video records; handwritten notes or notations in any
form; computer tapes, disks, and other data compilations from which information can be obtained and
any printouts thereof, including internet postings and email; attachments and enclosures; drafts of any
of the foregoing; and all non-identical copies or duplicates of any of the foregoing. For purposes of the
foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all or
part of a "document," whether or not such draft was superseded by a later draft and whether or not the
terms of the draft are the same as or different from the terms of the final document. The term shall also
include any computers or their hard drives that contain or contained any "documents".
13. The term "communication" broadly means all oral, written or electronic conversations, agreements,
inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal
devices, and includes all correspondence, transmittal slips, memoranda, email, internet postings, or
notes.
14. "Identify" means:
a. When used with reference to a document state:
i. The type of document (i.c., letter, memorandum, report, tape, printout, etc.);
ii. The individual who drafted or prepared the document;
iii. The present or last known location of the document or other identity of the individual who has
custody of the document; and
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PAGE 2iv. Other information sufficient to enable identification of the document, such as the addressee(s),
approximate length in pages, persons who received copies, and a synopsis of its contents.
b. When used with reference to a person, state its:
i. Name;
ii. Organizational status (i.¢., corporation, partnership, etc.);
iii. Business address; and
iv. Other similar identifying information, with the exception that if the person to be identified is
an individual then identify as in subparagraph (c).
c. When used with reference to an individual, state his or her:
i, Name;
ii. Last known residence address;
iii. Business address;
iv. Job title or position; and
v. Other similar identifying information.
d. When used with reference to a communication:
i. If written, identify the document as in subparagraph (a); and
ii. If oral, state the date of the communication and the individuals who sent, received and
otherwise had knowledge of the communication, and state the substance thereof.
15. "And" as well as "or" shall be construed either disjunctively or conjunctively as necessary to bring
within the scope of these requests any information which might otherwise be construed to be outside
their scope.
16. The terms "concern," "concerning," "relate to," "relates to," "relating to," and "relation to" means
consist of, refer to, reflect, or be in any way legally, logically, or factually connected with the matter
discussed.
II. INSTRUCTIONS
1. In response to these requests, you are required to furnish all information and/or documents in your
possession, custody, or control, or in the possession, custody or control of your past or present agents,
attorneys, accountants, advisors, employees, or any other persons acting on your behalf.
2. Wherever appropriate in these requests, the singular form of a word shall be interpreted as plural.
3. Wherever appropriate in these requests, the masculine form of a word shall be interpreted as feminine.
4. If you claim that any document is not subject to production on the basis of a privilege, you must
provide a separate log for every document you withhold, which identifies:
(a) The name, title and job or position of document's author;
(b) The name, title and job or position of document's sender;
(c) The name, title and job or position of every person who received or saw the document or any of its
copies;
(d) The date of the document;
(e) The physical description of the document, including size, length, typed or handwritten, etc.;
(f) A brief description of the document’s subject matter;
(g) The basis for the privilege asserted; and
(h) The name, title and job or position of all persons on behalf of whom the privilege is asserted.
5. The documents requested in this Request shall be produced in accordance with the requirements of
Rule 1.350.
III. DOCUMENTS REQUESTED
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PAGE 3Driver's License. Copies of front and back of your driver’s license (or government
issued identification card and social security card as they appear today).
2. IRS Income Tax Returns. Copies of your IRS Income Tax Returns, including all
schedules and amendments, for the years from Loan Inception through the present.
Ie
Employment Paychecks. Copies of all of Defendant(s)’ Employment Paychecks
and/or paystubs for the most recent six (6) months and for the six (6) months prior to
the date of the last payment made pursuant to the Mortgage referenced herein.
Is
Auto Lease. Copies of all current auto lease contract(s) or copies of all auto purchase
agreement(s) for all of Defendant(s)’ automobile(s) currently owned. If Defendant has
financed any of their automobiles, please produce copies of the monthly payment
statements for the past six (6) months for all financed automobiles.
Iv
Retirement Plans. Copies of any and all Retirement Plans, IRAs, 401 K Plans,
Pension Plans, or other Employment Benefit Plans (including but not limited to
annuity insurance plans, life insurance plans, etc.) for the past four (4) years wherein
Defendant is an owner, beneficiary, or contingent beneficiary of to which the
Defendant contributes.
Is
Stocks & Investments. Copies of any and all investment statements, brokerage
statements, stock accounts, stock option accounts, and/or mutual fund accounts
owned by the Defendant.
Ip
Life Insurance. Copies of any and all life insurance policies that either insure the life
of the Defendant or under which the Defendant is a beneficiary or contingent
beneficiary.
Ie
Credit Cards. Copies of and all credit card statements and any and all delinquency
notices for any of Defendant’s credit card accounts for the last three (3) years.
he
Checking Account. Copies of all of the Defendant’s checking account(s) and saving
account(s) statements for the six (6) months surrounding the March 1, 2018 date of
default. Specifically, plaintiff is seeking statements for the months of December
2017, January 2018, February 2018, March 2018, April 2018 and May 2018.
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PAGE 410. Home Files. Complete copy of your personal property/home file that contains
insurance information, closing loan documents, warranties, insurance claim
information (including payments on the claims), property tax information, and any
other documents/information relating to the subject property.
11. Deeds to Other Property. Copies of any and all deeds for any other real estate that the
Defendant has an ownership interest in currently or for any real estate that the
Defendant owned and sold in the past five (5) years.
12. Mortgages on Other Property. Copies of any and all mortgages and monthly mortgage
payment statements for any other real estate that the Defendant has an ownership
interest in currently or for any real estate that the Defendant owned and sold in the
ast five (5) years.
13. RESPA Documents. All preliminary or final disclosure documents given to you by
any person or company in connection with the loan. This request specifically
includes, but is not limited to, disclosures pursuant to Real Estate Settlement
Procedures Act (“RESPA”),
14. TILA Documents. All preliminary or final disclosure documents given to you by any
erson or company in connection with the loan. This request specifically includes,
but is not limited to, disclosures pursuant to Truth in Lending Act (“TILA”).
15. Good Faith Estimate. All preliminary or final disclosure documents given to you by
any person or company in connection with the loan. This request specifically
includes, but is not limited to, preliminary or final good-faith estimates.
16. HUD-1 Settlement Statement. All preliminary or final disclosure documents given to
you by any person or company in connection with the loan. This request specifically
includes, but is not limited to, preliminary and/or final HUD-1 Settlement Statements.
17. All Other Closing Documents. Any and all documents from the closing and/or
origination of the subject mortgage loan, including but not limited to all documents
Defendant received from the closing agent, mortgage broker and/or bank/lender.
18. Property Taxes. All copies of proof of payment for county property taxes, including
but not limited to any cancelled checks and/or any other documentation evidencing
payment of said taxes, from the date the property was purchased to the present.
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PAGE 519. Insurance Policy(s). All copies of proof of payment for property insurance (hazard and
flood), including but not limited to any cancelled checks and/or any other
documentation evidencing payment of said property insurance, from the date the
property was purchased to the present.
20. Lease(s). Copies of any written leases, contracts, or other documents, evidencing any
form of compensation e.g. rental income, services, etc., for the use of the premises by
any other individual(s), other than the Defendants, herein.
21. Water Bill. Copy of the most current water bill for the subject property.
22. Electric Bill. Copy of the most recent electric bill for the subject property.
23. Phone Bill. Copy of the most recent phone bill for the subject property.
24. Cable/Satellite Bill. Copy of the most recent cable or satellite bill for the subject
property.
25. Deed. Copy of your Deed to the subject property.
26. Listing Agreements. Copies of any and all listing agreements and executed or
proposed sales contracts for the subject property for the last three (3) years.
27. Other Mortgages on Property. Copies of any note and/or mortgage which have ever
encumbered or allegedly encumbered the subject property.
28. Modification(s). Copies of all modifications of the note and mortgage which are the
subject of this action, along with all other documents you or any defendant signed or
received relation to each such modification, and all other documents which you or any
defendant signed or received when you signed the modification.
29. Credit Restoration Documents. Any documents you have provided to or received from
any non-lawyer credit restoration or foreclosure assistance company.
30. Repayment Plan. Any proposed or agreed repayment plans and/or agreements
between you and Plaintiff, and/or between you and any loan servicer relating to the
Loan.
31. Forbearance Plan. Any proposed or agreed forbearance agreements between you and
Plaintiff, and/or between you and any loan servicer relating to the Loan.
32. Bankruptcy. Copies of all papers filed in any bankruptcy proceeding which you or any
defendant have filed or been involved in during the last ten (10) years.
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PAGE 633. Checks. Original(s) or copy(s) of personal check(s), cashiers check(s), money
order(s), written receipt(s), wire transfer(s) or any other document evidencing
payment(s) (front and back of document if in check form) made on the mortgage and
note in this matter.
34. Insurance. All copies of proof of payment for property insurance directly to the
subject insurer, then copies of any canceled checks and/or other documentation
evidencing payment for said insurance, from the date the property was purchased to
the present.
35. Taxes. All copies of proof of payment for county for property taxes, then copies of
any canceled checks and/or any other documentation evidencing payment of said
taxes from the date the property was purchased to the present.
36. HOA / Condominium Assessment Payments. All copies of copies of any canceled
checks and/or other proof of payment for HOA / Condominium Assessments, whether
general assessments or special assessments, and/or any other documentation
evidencing payment thereof, from the date the property was purchased to the present.
37. Statements. Original(s) or copy(s) of monthly statements, 1099-INT received
regarding the mortgage and note in this matter.
38. Documents Exchanged Between Defendant and Plaintiff. Any documents (expressly
including contracts, other written agreements, or communications) exchanged
between you and Plaintiff concerning the Property. This includes documents
memorializing, referencing or describing any oral or written communications, i.e.
handwritten notes taken during a telephone call.
39. Documents Exchanged Between Defendant and Third Parties. All documents relating
to this loan transaction that you provided to, or received from: (a) Original Lender;
(b) any title insurance company(ies) involved in this mortgage loan transaction; (c)
any settlement/closing agent (including any employees, agents or representatives of
the settlement/closing agent); (d) any mortgage broker(s). This includes all
documents that you filled out, prepared or signed in connection with the Loan.
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PAGE 740. Documents Sent. All documents, papers, letters, records, memos, notices, and
correspondence (including all envelopes and facsimile transmittal or delivery receipts)
sent by you or any defendant to Plaintiff at anytime.
41. Documents Received. All documents, papers, letters, records, memos, notices, and
correspondence (including all envelopes and facsimile transmittal or delivery receipts)
received by you or any defendant to Plaintiff at anytime.
42. Notice of Assignment. Any correspondence or other documents advising you that the
debt had been transferred or assigned.
43. Notice of Service Transfer. Any correspondence or other documents advising you of
transfer of servicing rights.
44. Failure to Perform. Any document (expressly including communications) between
you and any person relating to a failure by you to perform any contractual obligations
created by the Loan and/or Note.
45. Notice of Default. Any documents (expressly including communications) notifying
you that the Loan was in default or payments were not made when due.
46. Expert Witness Documents. All documents you have provided to or received from
any expert witness, consultant, investigator, or other agent, and any report or
document prepared, authored or drafted by such expert witness, consultant,
investigator or agent concerning or relating, in any respect, to any of the allegations or
claims in the complaint.
47. Witness Statements. All witness statements, affidavits, opinions or similar documents
obtained in connection with this lawsuit.
48. Affirmative Defense Documents. Any documents evidencing or supporting any
defense you may have to the lawsuit.
49. Refutation of Complaint Documents. Any documents evidencing or supporting any
refutation of the complaint in this lawsuit.
50. Fee Agreements. Copies of any and all fee arrangements or fee agreements between
you and your attorney(s) for your legal representation in this matter.
51. Transcriptions. Any and all transcriptions of any proceeding in this matter.
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PAGE 852. Exhibits. Any and all Exhibits, Models, Drawings, Plats, etc., or other documents
intended to be used at trial.
53. Interrogatories. Any and all documents that would support of any of the Answers to
Plaintiff's Interrogatories to Defendant(s) served in this matter.
54. Requests for Admission. Any and all documents that would support any denial or any
response other than admission to Plaintiff's Requests for Admission to Defendant(s)
in this matter.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the parties listed on the attached service list via Mail and/or E-mail in accordance with the
corresponding addresses listed therein on this 11 day of November, 2020.
ROBERTSON, ANSCHUTZ & SCHNEID, P.L.
Attorney for Plaintiff
6409 Congress Ave., Suite 100
Boca Raton, FL 33487
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: mail@rasflaw.com
By: _\S\Scott Brown_
Scott Brown, Esquire
Florida Bar No. 88187
Communication Email: sbrown@rasflaw.com
SERVICE LIST
LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
ANTHONY N. LEGENDRE II, ESQUIRE
ATTORNEY FOR MICHAEL R. PARKEY
C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
P.O. BOX 948599
MAITLAND, FL 32794
PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM
SECONDARY EMAIL: ANTHONY @LAW-LEGENDS.COM
LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
ANTHONY N. LEGENDRE II, ESQUIRE
ATTORNEY FOR MARK D. PARKEY
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PAGE 9C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
P.O. BOX 948599
MAITLAND, FL 32794
PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM
SECONDARY EMAIL: ANTHONY @LAW-LEGENDS.COM
UNKNOWN PARTY #1 N/K/A CHRISTINE DEVORE
1355 JAN LAN BLVD
SAINT CLOUD, FL 34772
20-060827 - KrV
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Filing # 116722161 E-Filed 11/16/2020 02:16:46 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 2018-CA-003041-MF HOMEBRIDGE FINANCIAL SERVICES, INC., Plaintiff, vs. MICHAEL R. PARKEY AND MARK D. PARKEY, et. al., Defendant(s). / PLAINTIFF'S FIRST REQUEST FOR. PRODUCTION OF DOCUMENTS TO DEFENDANT PLAINTIFF, NEWREZ LLC D/B/A SHELLPOINT MORTGAGE SERVICING, by and through the undersigned attorney, pursuant to Florida Rule of Civil Procedure 1.350, serves the following First Request for Production of Documents to Defendant, MARK D. PARKEY, and requests within thirty (30) days hereof the production for inspection and copying at the offices of Robertson, Anschutz & Schneid, P.L., 6409 Congress Avenue, Suite 100, or such alternative location as the parties may agree, the documents designated below that are in their possession, custody, or control, as well as written responses to these requests. I. DEFINITIONS For purposes of this Request for Production of Documents, the following definitions and instructions apply and are incorporated into each Request as though fully stated therein: 1. "Loan" means the loan at issue in this action memorialized by that certain promissory note described below. 2. “Note” means that certain promissory note executed by Defendant(s) Borrower(s) which is at issue and the subject of this action. 20-060827 - KrV PAGE 13. “Mortgage” means that certain mortgage, which is at issue in this action, executed by Defendant(s) Borrower(s) to secure the Loan and/or Note. 4. "Property" refers to the property secured by the Mortgage, and defined specifically in the Mortgage attached to Plaintiff's complaint subject to Plaintiff's foreclosure in the above-captioned case. 5. “Borrower(s)” means the person(s) who executed the Note and Mortgage listed above. 6. “Original Lender” means the lender listed on the Note. 7. “Lawsuit" means the action initiated by Plaintiff against you by filing the complaint. 8. "Persons" refers to and includes a corporation, partnership, joint venture, proprietorship, firm, company, unincorporated association, individual, association of individuals, or any other such entity. 9. "Individual" means a natural person. 10. "You" (including "your" and "yours") and “Defendant(s)” shall refer to Defendant(s) Borrower(s) named above in the case style of this action, and any consultants, attorneys, experts, investigators, agents or other persons acting on your behalf. 11. "Plaintiff" means Plaintiff named above in the case style of this action, its counsel, and any of its officers, directors, affiliates, shareholders, attorneys, consultants, experts, investigators, agents or other persons acting on its behalf, including any current and prior loan servicers. 12. The term "document" has the broadest meaning accorded to it and includes without limitation all written, typed, printed, reproduced, filmed, electronically or computer-stored, or recorded material or information of any kind, in the possession, custody, or control of you or any of your past or present agents, employees, consultants, attorneys or other persons acting on your behalf, including but not limited to any of the following: correspondence; letters; memoranda; interoffice memoranda; writings; notes; notebooks; maps; sketches; charts; films and microfilm; studies; plans; analyses; work papers; statistical records; bills and other billing records; receipts; books; press releases; reports; contracts and agreements; records; summaries; memorials; minutes; agendas or notes of meetings; conferences; telephone calls or other conversations; calendars and diaries; appointment books and message pads; photographs; tape recordings or other audio or video records; handwritten notes or notations in any form; computer tapes, disks, and other data compilations from which information can be obtained and any printouts thereof, including internet postings and email; attachments and enclosures; drafts of any of the foregoing; and all non-identical copies or duplicates of any of the foregoing. For purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a "document," whether or not such draft was superseded by a later draft and whether or not the terms of the draft are the same as or different from the terms of the final document. The term shall also include any computers or their hard drives that contain or contained any "documents". 13. The term "communication" broadly means all oral, written or electronic conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes all correspondence, transmittal slips, memoranda, email, internet postings, or notes. 14. "Identify" means: a. When used with reference to a document state: i. The type of document (i.c., letter, memorandum, report, tape, printout, etc.); ii. The individual who drafted or prepared the document; iii. The present or last known location of the document or other identity of the individual who has custody of the document; and 20-060827 - KrV PAGE 2iv. Other information sufficient to enable identification of the document, such as the addressee(s), approximate length in pages, persons who received copies, and a synopsis of its contents. b. When used with reference to a person, state its: i. Name; ii. Organizational status (i.¢., corporation, partnership, etc.); iii. Business address; and iv. Other similar identifying information, with the exception that if the person to be identified is an individual then identify as in subparagraph (c). c. When used with reference to an individual, state his or her: i, Name; ii. Last known residence address; iii. Business address; iv. Job title or position; and v. Other similar identifying information. d. When used with reference to a communication: i. If written, identify the document as in subparagraph (a); and ii. If oral, state the date of the communication and the individuals who sent, received and otherwise had knowledge of the communication, and state the substance thereof. 15. "And" as well as "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of these requests any information which might otherwise be construed to be outside their scope. 16. The terms "concern," "concerning," "relate to," "relates to," "relating to," and "relation to" means consist of, refer to, reflect, or be in any way legally, logically, or factually connected with the matter discussed. II. INSTRUCTIONS 1. In response to these requests, you are required to furnish all information and/or documents in your possession, custody, or control, or in the possession, custody or control of your past or present agents, attorneys, accountants, advisors, employees, or any other persons acting on your behalf. 2. Wherever appropriate in these requests, the singular form of a word shall be interpreted as plural. 3. Wherever appropriate in these requests, the masculine form of a word shall be interpreted as feminine. 4. If you claim that any document is not subject to production on the basis of a privilege, you must provide a separate log for every document you withhold, which identifies: (a) The name, title and job or position of document's author; (b) The name, title and job or position of document's sender; (c) The name, title and job or position of every person who received or saw the document or any of its copies; (d) The date of the document; (e) The physical description of the document, including size, length, typed or handwritten, etc.; (f) A brief description of the document’s subject matter; (g) The basis for the privilege asserted; and (h) The name, title and job or position of all persons on behalf of whom the privilege is asserted. 5. The documents requested in this Request shall be produced in accordance with the requirements of Rule 1.350. III. DOCUMENTS REQUESTED 20-060827 - KrV PAGE 3Driver's License. Copies of front and back of your driver’s license (or government issued identification card and social security card as they appear today). 2. IRS Income Tax Returns. Copies of your IRS Income Tax Returns, including all schedules and amendments, for the years from Loan Inception through the present. Ie Employment Paychecks. Copies of all of Defendant(s)’ Employment Paychecks and/or paystubs for the most recent six (6) months and for the six (6) months prior to the date of the last payment made pursuant to the Mortgage referenced herein. Is Auto Lease. Copies of all current auto lease contract(s) or copies of all auto purchase agreement(s) for all of Defendant(s)’ automobile(s) currently owned. If Defendant has financed any of their automobiles, please produce copies of the monthly payment statements for the past six (6) months for all financed automobiles. Iv Retirement Plans. Copies of any and all Retirement Plans, IRAs, 401 K Plans, Pension Plans, or other Employment Benefit Plans (including but not limited to annuity insurance plans, life insurance plans, etc.) for the past four (4) years wherein Defendant is an owner, beneficiary, or contingent beneficiary of to which the Defendant contributes. Is Stocks & Investments. Copies of any and all investment statements, brokerage statements, stock accounts, stock option accounts, and/or mutual fund accounts owned by the Defendant. Ip Life Insurance. Copies of any and all life insurance policies that either insure the life of the Defendant or under which the Defendant is a beneficiary or contingent beneficiary. Ie Credit Cards. Copies of and all credit card statements and any and all delinquency notices for any of Defendant’s credit card accounts for the last three (3) years. he Checking Account. Copies of all of the Defendant’s checking account(s) and saving account(s) statements for the six (6) months surrounding the March 1, 2018 date of default. Specifically, plaintiff is seeking statements for the months of December 2017, January 2018, February 2018, March 2018, April 2018 and May 2018. 20-060827 - KrV PAGE 410. Home Files. Complete copy of your personal property/home file that contains insurance information, closing loan documents, warranties, insurance claim information (including payments on the claims), property tax information, and any other documents/information relating to the subject property. 11. Deeds to Other Property. Copies of any and all deeds for any other real estate that the Defendant has an ownership interest in currently or for any real estate that the Defendant owned and sold in the past five (5) years. 12. Mortgages on Other Property. Copies of any and all mortgages and monthly mortgage payment statements for any other real estate that the Defendant has an ownership interest in currently or for any real estate that the Defendant owned and sold in the ast five (5) years. 13. RESPA Documents. All preliminary or final disclosure documents given to you by any person or company in connection with the loan. This request specifically includes, but is not limited to, disclosures pursuant to Real Estate Settlement Procedures Act (“RESPA”), 14. TILA Documents. All preliminary or final disclosure documents given to you by any erson or company in connection with the loan. This request specifically includes, but is not limited to, disclosures pursuant to Truth in Lending Act (“TILA”). 15. Good Faith Estimate. All preliminary or final disclosure documents given to you by any person or company in connection with the loan. This request specifically includes, but is not limited to, preliminary or final good-faith estimates. 16. HUD-1 Settlement Statement. All preliminary or final disclosure documents given to you by any person or company in connection with the loan. This request specifically includes, but is not limited to, preliminary and/or final HUD-1 Settlement Statements. 17. All Other Closing Documents. Any and all documents from the closing and/or origination of the subject mortgage loan, including but not limited to all documents Defendant received from the closing agent, mortgage broker and/or bank/lender. 18. Property Taxes. All copies of proof of payment for county property taxes, including but not limited to any cancelled checks and/or any other documentation evidencing payment of said taxes, from the date the property was purchased to the present. 20-060827 - KrV PAGE 519. Insurance Policy(s). All copies of proof of payment for property insurance (hazard and flood), including but not limited to any cancelled checks and/or any other documentation evidencing payment of said property insurance, from the date the property was purchased to the present. 20. Lease(s). Copies of any written leases, contracts, or other documents, evidencing any form of compensation e.g. rental income, services, etc., for the use of the premises by any other individual(s), other than the Defendants, herein. 21. Water Bill. Copy of the most current water bill for the subject property. 22. Electric Bill. Copy of the most recent electric bill for the subject property. 23. Phone Bill. Copy of the most recent phone bill for the subject property. 24. Cable/Satellite Bill. Copy of the most recent cable or satellite bill for the subject property. 25. Deed. Copy of your Deed to the subject property. 26. Listing Agreements. Copies of any and all listing agreements and executed or proposed sales contracts for the subject property for the last three (3) years. 27. Other Mortgages on Property. Copies of any note and/or mortgage which have ever encumbered or allegedly encumbered the subject property. 28. Modification(s). Copies of all modifications of the note and mortgage which are the subject of this action, along with all other documents you or any defendant signed or received relation to each such modification, and all other documents which you or any defendant signed or received when you signed the modification. 29. Credit Restoration Documents. Any documents you have provided to or received from any non-lawyer credit restoration or foreclosure assistance company. 30. Repayment Plan. Any proposed or agreed repayment plans and/or agreements between you and Plaintiff, and/or between you and any loan servicer relating to the Loan. 31. Forbearance Plan. Any proposed or agreed forbearance agreements between you and Plaintiff, and/or between you and any loan servicer relating to the Loan. 32. Bankruptcy. Copies of all papers filed in any bankruptcy proceeding which you or any defendant have filed or been involved in during the last ten (10) years. 20-060827 - KrV PAGE 633. Checks. Original(s) or copy(s) of personal check(s), cashiers check(s), money order(s), written receipt(s), wire transfer(s) or any other document evidencing payment(s) (front and back of document if in check form) made on the mortgage and note in this matter. 34. Insurance. All copies of proof of payment for property insurance directly to the subject insurer, then copies of any canceled checks and/or other documentation evidencing payment for said insurance, from the date the property was purchased to the present. 35. Taxes. All copies of proof of payment for county for property taxes, then copies of any canceled checks and/or any other documentation evidencing payment of said taxes from the date the property was purchased to the present. 36. HOA / Condominium Assessment Payments. All copies of copies of any canceled checks and/or other proof of payment for HOA / Condominium Assessments, whether general assessments or special assessments, and/or any other documentation evidencing payment thereof, from the date the property was purchased to the present. 37. Statements. Original(s) or copy(s) of monthly statements, 1099-INT received regarding the mortgage and note in this matter. 38. Documents Exchanged Between Defendant and Plaintiff. Any documents (expressly including contracts, other written agreements, or communications) exchanged between you and Plaintiff concerning the Property. This includes documents memorializing, referencing or describing any oral or written communications, i.e. handwritten notes taken during a telephone call. 39. Documents Exchanged Between Defendant and Third Parties. All documents relating to this loan transaction that you provided to, or received from: (a) Original Lender; (b) any title insurance company(ies) involved in this mortgage loan transaction; (c) any settlement/closing agent (including any employees, agents or representatives of the settlement/closing agent); (d) any mortgage broker(s). This includes all documents that you filled out, prepared or signed in connection with the Loan. 20-060827 - KrV PAGE 740. Documents Sent. All documents, papers, letters, records, memos, notices, and correspondence (including all envelopes and facsimile transmittal or delivery receipts) sent by you or any defendant to Plaintiff at anytime. 41. Documents Received. All documents, papers, letters, records, memos, notices, and correspondence (including all envelopes and facsimile transmittal or delivery receipts) received by you or any defendant to Plaintiff at anytime. 42. Notice of Assignment. Any correspondence or other documents advising you that the debt had been transferred or assigned. 43. Notice of Service Transfer. Any correspondence or other documents advising you of transfer of servicing rights. 44. Failure to Perform. Any document (expressly including communications) between you and any person relating to a failure by you to perform any contractual obligations created by the Loan and/or Note. 45. Notice of Default. Any documents (expressly including communications) notifying you that the Loan was in default or payments were not made when due. 46. Expert Witness Documents. All documents you have provided to or received from any expert witness, consultant, investigator, or other agent, and any report or document prepared, authored or drafted by such expert witness, consultant, investigator or agent concerning or relating, in any respect, to any of the allegations or claims in the complaint. 47. Witness Statements. All witness statements, affidavits, opinions or similar documents obtained in connection with this lawsuit. 48. Affirmative Defense Documents. Any documents evidencing or supporting any defense you may have to the lawsuit. 49. Refutation of Complaint Documents. Any documents evidencing or supporting any refutation of the complaint in this lawsuit. 50. Fee Agreements. Copies of any and all fee arrangements or fee agreements between you and your attorney(s) for your legal representation in this matter. 51. Transcriptions. Any and all transcriptions of any proceeding in this matter. 20-060827 - KrV PAGE 852. Exhibits. Any and all Exhibits, Models, Drawings, Plats, etc., or other documents intended to be used at trial. 53. Interrogatories. Any and all documents that would support of any of the Answers to Plaintiff's Interrogatories to Defendant(s) served in this matter. 54. Requests for Admission. Any and all documents that would support any denial or any response other than admission to Plaintiff's Requests for Admission to Defendant(s) in this matter. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the parties listed on the attached service list via Mail and/or E-mail in accordance with the corresponding addresses listed therein on this 11 day of November, 2020. ROBERTSON, ANSCHUTZ & SCHNEID, P.L. Attorney for Plaintiff 6409 Congress Ave., Suite 100 Boca Raton, FL 33487 Telephone: 561-241-6901 Facsimile: 561-997-6909 Service Email: mail@rasflaw.com By: _\S\Scott Brown_ Scott Brown, Esquire Florida Bar No. 88187 Communication Email: sbrown@rasflaw.com SERVICE LIST LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC ANTHONY N. LEGENDRE II, ESQUIRE ATTORNEY FOR MICHAEL R. PARKEY C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC P.O. BOX 948599 MAITLAND, FL 32794 PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM SECONDARY EMAIL: ANTHONY @LAW-LEGENDS.COM LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC ANTHONY N. LEGENDRE II, ESQUIRE ATTORNEY FOR MARK D. PARKEY 20-060827 - KrV PAGE 9C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC P.O. BOX 948599 MAITLAND, FL 32794 PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM SECONDARY EMAIL: ANTHONY @LAW-LEGENDS.COM UNKNOWN PARTY #1 N/K/A CHRISTINE DEVORE 1355 JAN LAN BLVD SAINT CLOUD, FL 34772 20-060827 - KrV PAGE 10