IN THE SUPREME COURT OF KINGS COUNTY

STATE OF NEW YORK

ABC
Plaintiff
Vs. Index No: 12236/07
XYZ
Defendants

DEFENDANTS MOTION REQUESTING PLAINTIFF TO PRODUCE

DOCUMENTS, INTERROGATORIES AND ADMISSIONS

COMES NOW DEFENDANT, XYZ, and files this Motion requesting Plaintiffs,
ABC, in its capacity as the Lender as per the Mortgage Deed dated 28th February 2008
to produce the Documents, Interrogatories and Admissions.

Request for Production of Documents

Pursuant to the New York Civil Practice Law and Rules Section 3120 the Defendant,
Andrea Davilar hereby request that the named Plaintiff, Option One Mortgage
Corporation to produce the following documents for inspection and copying at a
location within the venue of the Supreme Court of the Kings County, New York,
within thirty days of this request. Andrea Davilar asks to be informed of the date, time
and place where the requested documents can be copied by her or her agent or in the
alternative, Option One Mortgage Corporation may furnish a legible, true and correct
copy of each requested documents to Andrea Davilar at her mailing address as given
below except for the requested Promissory Note are to be served upon Andrea Davilar
within thirty (30) days after service of this request for production of documents.

Andrea Davilar request the Counsel purporting to represent Option One Mortgage
Corporation, within 30 days of this request for production of these documents, set a
hearing with the Court for viewing of the original Promissory Note.

Instructions to Request for Production of Documents

1. This request for production of documents is directed towards all information
known or available to Option One Mortgage Corporation including
information contained in the records and documents in Option One Mortgage
Corporations custody or control or available to Option One Mortgage
Corporation upon reasonable inquiry. Where requested documents does not
exist please state the documents does not exist.
2. Each request for production of documents is to be deemed a continuing one. If
after serving any requested document, an authorized officer of Option One
Mortgage Corporation obtains any further documentation pertaining to that
request for production, Option One Mortgage Corporation is requested to
serve a supplemental answer setting forth copies of additional documents.

Definitions
1. Option One Mortgage Corporation includes any and all persons acting in
concert with Option One Mortgage Corporation.
2. “Document” includes every piece of paper held in Option One Mortgage
Corporations possession or generated by Option One Mortgage Corporation.
3. “GSE” means Government Sponsored Entity.
4. “MERS” means Mortgage Electronic Registration System.
5. “Nominal Lender” means and includes the Special Purpose Entity which has
been constituted by the Option One Mortgage Corporation.
6. “Andrea Davilar” includes all nick names, pseudonyms and / or misnomers in
any paper or documents referencing the Defendant or any liability or
obligation attributable to her, including Andrea A. Davilar

Documents Requested
1. Subject to the foregoing conditions, produce the original Promissory Note
alleged to have been signed by Andrea Davilar as per the loan bearing No:
331044918. If none, state “none”.
2. Produce the Order relieving Mr. Leo S. Ortega as the Vice President of
Deutsche Bank on or after 19th June 2007 which entitle him to join as the Vice
President of Option One Mortgage Corporation and to sign the Affidavit of
Merit and the Amount Due on behalf of Option One Mortgage Corporation on
28th June 2007. If none, state “none”.
 3. Produce if any certified or uncertified security used for the funding of this
account. If none, state “none”.
4. Produce any and all "Pooling Agreement(s)" between the nominal lender at the
loan closing and any party or parties who could claim an interest in the loan
closing or documents pertaining thereto and any GSE or other party. If none,
state “none”.
5. Produce any and all "Deposit Agreement(s)" between the nominal lender at the
loan closing and any party or parties who could claim an interest in the loan
closing or documents pertaining thereto and any GSE or other party. If none,
state “none”.
6. Produce any and all "Servicing Agreement(s)" between the nominal lender at
the loan closing and any party or parties who could claim an interest in the
loan closing or documents pertaining thereto and any GSE or other party. If
none, state “none”.
7. Produce any and all "Custodial Agreement(s)" between the nominal lender at
the loan closing and any party or parties who could claim an interest in the
loan closing or documents pertaining thereto and any GSE or other party. If
none, state “none”.
8. Produce any and all "Master Purchasing Agreement(s)" between the nominal
lender at the loan closing and any party or parties who could claim an interest
in the loan closing or documents pertaining thereto and any GSE or other
party. If none, state “none”.
9. Produce any and all "Issuer Agreement(s)" between the nominal lender at the
loan closing and any party or parties who could claim an interest in the loan
closing or documents pertaining thereto and any GSE or other party. If none,
state “none”.
10. Produce any and all "Commitment to Guarantee Agreement(s)” between the
nominal lender at the loan closing and any party or parties who could claim an
interest in the loan closing or documents pertaining thereto and any GSE or
other party. If none, state “none”.
11. Produce any and all "Release of Document Agreement(s)” between the
nominal lender at the loan closing and any party or parties who could claim an
interest in the loan closing or documents pertaining thereto and any GSE or
other party. If none, state “none”.
12. Produce any and all "Master Agreement for Servicer’s Principal and Interest
Custodial Account" between the nominal lender at the loan closing and any
party or parties who could claim an interest in the loan closing or documents
pertaining thereto and any GSE or other party. If none, state “none”.
13. Produce any and all "Servicer's Escrow Custodial Account" between the
nominal lender at the loan closing and any party or parties who could claim an
interest in the loan closing or documents pertaining thereto and any GSE or
other party. If none, state “none”.
14. Produce any and all "Release of Interest Agreement(s)” between the nominal
lender at the loan closing and any party or parties who could claim an interest
in the loan closing or documents pertaining thereto and any GSE or other
party. If none, state “none”.
15. Produce any and all “Trustee Agreement(s)” between the nominal lender at the
loan closing and any party or parties who could claim an interest in the loan
closing or documents pertaining thereto and trustee(s) regarding this account
or pool accounts with any GSE or other party. If none, state “none”.
16. Produce any and all document(s) evidencing any trust relationship regarding
the Mortgage or and any Note in this matter. If none, state “none”.
17. Produce any and all document(s) establishing any Trustee of record for the
Mortgage or and any Note in this matter. If none, state “none”.
18. Produce any and all document(s) establishing the date of any appointment of
Trustee for the Mortgage or and any Note, including any and all assignments
or transfers or nominees of any substitute trustees(s). If none, state “none”.
19. Produce any and all document(s) establishing any Grantor for this Mortgage or
and any Note in this matter. If none, state “none”.
20. Produce any and all document(s) establishing any Grantee for this Mortgage
or and any Note in this matter. If none, state “none”.
21. Produce any and all document(s) establishing any Beneficiary for this
Mortgage or and any Note in this matter. If none, state “none”.
22. Produce any and all document(s) evidencing the Mortgage. If none, state
“none”.
23. Produce all data, information, notations, text, figures and information
contained in your mortgage servicing and accounting computer systems
including, but not limited to Alltel or Fidelity CPI system, or any other similar
 mortgage servicing software used by you, any servicers, or sub-servicers of
this mortgage account from the inception of this account to the date written
above. If none, state “none”.
24. Produce all descriptions and legends of all Codes used in Option One
Mortgage Corporations mortgage servicing and accounting system so as to
enable the examiners and auditors and experts retained to audit and review
this mortgage account to properly carry on their work. If none, state “none”.
25. Produce all assignments, transfers, allonge, or other documents evidencing a
transfer, sale or assignment of this mortgage, deed of trust, monetary
instrument or other document that secures payment by Andrea Davilar to this
obligation in this account from the inception of this account to the present date
including any such assignment on MERS. If none, state “none”.
26. Produce all deeds in lieu, modifications to this mortgage, monetary instrument
or deed of trust from the inception of this account to the present date. If none,
state “none”.
27. Produce the front and back of each and every canceled check, money order,
draft, debit or credit notice issued to any servicers of this account for payment
of any monthly payment, other payment, escrow charge, fee or expense on this
account. If none, state “none”.
28. Produce all escrow analyses conducted on this account from the inception of
this account until the date of this letter. If none, state “none”.
29. Produce the front and back of each and every canceled check, draft or debit
notice issued for payment of closing costs, fees and expenses listed on any and
all disclosure statements including, but not limited to, appraisal fees,
inspection fees, title searches, title insurance fees, credit life insurance
premiums, hazard insurance premiums, commissions, attorney fees, points,
etc. If none, state “none”.
30. Produce front and back copies of all payment receipts, checks, money orders,
drafts, automatic debits and written evidence of payments made by Andrea
Davilar or others on this account. If none, state “none”.
31. Produce all letters, statements and documents sent to Andrea Davilar by
Option One Mortgage Corporation. If none, state “none”.
32. Produce all letters, statements and documents sent to Andrea Davilar by
agents, attorneys or representatives of Option One Mortgage Corporation. If
none, state “none”.
33. Produce all letters, statements and documents sent to Andrea Davilar by
previous servicers, sub-servicers or others in the account file or under the
control or possession or in the control or possession of any affiliate, parent
company, agent, servicers, sub-servicers, attorney or other representative of
Option One Mortgage Corporation. If none, state “none”.
34. Produce all letters, statements and documents contained in the account file of
Andrea Davilar or imaged by Option One Mortgage Corporation, any
servicers or sub-servicers of this mortgage from the inception of this account
to the present date. If none, state “none”.
35. Produce all electronic transfers, assignments and sales of the note or asset,
mortgage, deed of trust or other security instrument. If none, state “none”.
36. Produce all copies of property inspection reports, appraisals, BPO s and
reports done on the property of Andrea Davilar. If none, state “none”.
37. Produce all invoices for each charge such as inspection fees, BPO s, appraisal
fees, attorney fees, insurance, taxes, assessments or any expense which has
been charged to this mortgage account from the inception of this account to
the present date. If none, state “none”.
38. Produce all checks used to pay invoices for each charge such as inspection
fees, BPO s, appraisal fees, attorney fees, insurance, taxes, assessments or any
expense which has been charged to this account from the inception of this
account to the present date. If none, state “none”.
39. Produce all agreements, contracts and understandings with vendors that have
been paid for any charge on this account from the inception of this account to
the present date. If none, state “none”.
40. Produce all account servicing records, payment payoffs, payoff calculations,
ARM audits, interest rate adjustments, payment records, transaction histories,
account histories, accounting records, ledgers, and documents that relate to the
accounting of this account from the inception of this account to the present
date. If none, state “none”.
 41. Produce all account servicing transaction records, ledgers, registers and
similar items detailing how this account has been serviced from the inception
of this account to the present date. If none, state “none”.
42. Produce all sales contracts, servicing agreements, assignments, alonges,
transfers, indemnification agreements, recourse agreements and any agreement
related to this account from the inception of this account to the present date.
43. Provide copies of all invoices and detailed billing statements from any law
firm or attorney that has billed such fees that have been assessed or collected
from this account from the inception to the present date.

Requests for Admissions

YOU ARE REQUIRED, pursuant to the New York Civil Practice Law and Rules
Section 3123, by and through an authorized officer of your Company, to answer
completely, in writing and under oath, the following request of Admission, and to
return your answers to this request for admissions to Andrea Davilar at her mailing
address indicated below, within thirty days of the date of service of these request for
admissions.

Instructions to Request for Admissions

1. These requests for Admissions are directed towards all information known or
available to Plaintiff Option One Mortgage Corporation including information
contained in the records and documents in Option One Mortgage Corporations
custody or control or available to Option One Mortgage Corporation upon
reasonable enquiry. Your answer to each request for admission shall
specifically deny the matter, or set forth in detail the reasons why you cannot
truthfully admit or deny the matter. Where request for admission cannot be
answered in full they shall be answered as completely as possible and
incomplete answers shall be accompanied by a specification of the reasons for
the incompleteness of the answer and of whatever actual knowledge is
possessed with respect to each unanswered or incompletely answered request
for admission.
2. Each request for admission is to deemed a continuing one. If after serving an
answer to any request for admission, an authorized officer of Option One
 Mortgage Corporation obtains any further information pertaining to that
request for admission, the authorized officer for Option One Mortgage
Corporation is requested to serve a supplemental answer setting forth such
information.
3. As to every request for an admission which an authorized officer for Option
One Mortgage Corporation fails to answer in whole or in part, the subject
matter of that admission will be deemed confessed and stipulated as fact to
the court.

Definitions
1. “You” and “your” includes Option One Mortgage Corporation any and all
persons acting in concert with Option One Mortgage Corporation.
2. “Document” includes every piece of paper held in Option One Mortgage
Corporations possession or generated by Option One Mortgage Corporation.
3. “Nominal Lender” means and includes the Special Purpose Entity which has
been constituted by the Option one Mortgage Corporation.
4. “Andrea Davilar” includes all nick names, pseudonyms and / or misnomers in
any paper or documents referencing the Defendant or any liability or
obligation attributable to her, including Andrea A. Davilar.

Admissions Requested
1. Admit or deny that Option One Mortgage Corporation has assigned the
Promissory Note and Mortgage Deed to a third party.
Admitted
Denied
2. Admit or deny that Option One Mortgage Corporation has no standing to
initiate foreclosure proceedings against Andrea Davilar.
Admitted
Denied
3. Admit or deny that Leo S. Ortega is not the authorized person to swear the
Affidavit of Merit.
Admitted
Denied
 4. Admit or deny that proper statutory disclosures regarding the mortgage, its
interest and other related charges and mode of payment has been made to
Andrea Davilar.
Admitted
Denied
5. Admit or deny that Summons has been served properly on Andrea Davilar in
this case.
Admitted
Denied

Interrogatories

YOU ARE REQUIRED, pursuant to the New York Civil Practice Law and Rules
Sections 3131, 3132 and 3133, by and through an authorized officer of the your
Company, to answer completely in writing, and under oath, the following
Interrogatories, and to return your answers to these Interrogatories to Andrea Daviler
at her mailing address indicated below, within thirty days of the date of service of
these Interrogatories.

Instructions to these Interrogatories

1. These interrogatories are directed towards all information known or available

to the Plaintiff, Option One Mortgage Bank including information contained
in the records and the documents in Option One Mortgage Banks custody or
control or available to Option One Mortgage Bank upon reasonable enquiry.
Where interrogatories cannot be answered in full, they shall be answered as
completely as possible and incomplete answers shall be accompanied by a
specification of the reasons for the incompleteness of the answer and of
whatever actual knowledge is possessed with respect to each unanswered or
incompletely answered interrogatory. If sufficient space for your answer is not
provided herein, you may attach additional papers with your answers and refer
to your attached answers in the space provided herein.
2. Each interrogatory is to be deemed a continuing one. If, after serving an
answer to any interrogatory, an authorized officer for Option One Mortgage
Bank obtains any further information pertaining to that interrogatory, the
 authorized officer of Option One Mortgage Corporation is requested to serve a
supplemental answer setting forth such information.

Definitions
1. “You” and “your” includes Option One Mortgage Corporation any and all
persons acting in concert with Option One Mortgage Corporation.
2. “Document” includes every piece of paper held in Option One Mortgage
Corporations possession or generated by Option One Mortgage Corporation.
3. “GSE” means Government Sponsored Entity.
4. “MERS” means Mortgage Electronic Registration System.
5. “Nominal Lender” means and includes the Special Purpose Entity which has
been constituted by the Option one Mortgage Corporation.
6. “Andrea Davilar” includes all nick names, pseudonyms and / or misnomers in
any paper or documents referencing the Defendant or any liability or
obligation attributable to her, including Andrea A. Davilar.

Interrogatories
1. State the name, job title and business address of each person providing
information in response to these discovery requests.

2. State the type of business organization Option One Mortgage Corporation is

and name every State of the union in which it is chartered or registered.

3. Identify for each account accounting and servicing system used by Option One
Mortgage Corporation and any sub-servicers or previous servicers from the
inception of this account to the present date which enable the experts to
decipher the data provided.
4. For each account accounting and servicing system identified by Option One
Mortgage Corporation and any sub-servicers or previous servicers from the
inception of this account to the present date, state the name and address of the
company that designed and sold the system.

5. For each account accounting and servicing system used by Option One
Mortgage Corporation and any sub-servicers or previous servicers from the
inception of this account to the present date, please provide the complete
transaction code list for each system so that Andrea Davilar and others can
adequately audit this account.

6. In a spreadsheet form or in letter form in a columnar format, detail each and

every credit on this account from the date such credit was posted to this
account as well as the date any credit was received.

7. In a spreadsheet form or in letter form in a columnar format, detail each and

every debit on this account from the date such debit was posted to this account
as well as the date any debit was received.

8. For each debit and credit listed, state the definition for each corresponding
transaction code Option One Mortgage Corporation utilize.

9. For each transaction code, provide the master transaction code list used by
Option One Mortgage Corporation or previous servicers.
10. Has each sale, transfer or assignment of this mortgage, monetary instrument,
deed of trust or any other instrument Andrea Davilar executed to secure this
debt been recorded in the county property records in the county and state in
which Andrea Davilers property is located from the inception of this account
to the present date? State Yes or No.

11. If No, why?

12. Is Option One Mortgage Corporation the servicer of this mortgage account or
the holder in due course and beneficial owner of this mortgage, monetary
instrument and /or deed of trust? State Yes or No.

13. Have any sales, transfers or assignments of this mortgage, monetary

instrument, deed of trust or any other instrument executed by Andrea Davilar
to secure this debt been recorded in any electronic fashion such as MERS or
other internal or external recording system from the inception of this account
to the present date? State Yes or No.

14. If yes, give details of the names of the seller, purchaser, assignor, assignee or
any holder in due course to any right or obligation of any note, mortgage, deed
of trust or security instrument executed by Andrea Davilar securing the
obligation on this account that was not recorded in the county records where
my property is located whether they be mortgage servicing rights or the
beneficial interest in the principal and interest payments.
15. Did the originator or previous servicers of this account have any financing
agreements or contracts with Option One Mortgage Corporation or an affiliate
of Option One Mortgage Corporation?

16. Did the originator or previous servicers of this account have any financing
agreements or contracts with Option One Mortgage Corporation or an affiliate
of Option One Mortgage Corporation?

17. Did the originator or previous servicers of this account receive any
compensation, fee, commission, payment, rebate or other financial
consideration from Option One Mortgage Corporation or affiliate of Option
One Mortgage Corporation for handling, processing, originating or
administering this loan? If yes, please describe and itemize each and every
form of compensation, fee, commission, payment, rebate or other financial
consideration paid to the originator of this account by your company or any
affiliate.

18. State where the originals of this entire account file are currently located and
how they are being stored, kept and protected.

19. Where is the original monetary instrument or mortgage Andrea Davilar signed
located? Give details of its physical location and whether anyone is holding
the Promissory Note as a custodian or trustee?

20. Where is the original deed of trust or mortgage and Promissory Note signed by
Andrea Davilar placed? Give details of its physical location and whether
anyone holding this Note as a custodian or trustee?
21. State whether since the inception of this account, there has been any
assignment of Andrea Davilar’s monetary instrument / asset to any other
party? If the answer is yes, give details of the names and addresses of each and
every individual, party, bank, trust or entity that has received such
assignments.

22. State whether since the inception of this account there has been any
assignment of the deed of trust or mortgage and Promissory Note to any other
party? If the answer is yes, give details of the names and addresses of each and
every individual, party, bank, trust or entity that has received such
assignments.

23. State whether since the inception of this account, there has been any sale or
assignment of the servicing rights to this mortgage account to any other party?
If the answer is yes, give details of the names and addresses of each and every
individual, party, bank, trust or entity that has received such assignments or
sale.

24. State whether since the inception of this account, there has been any sub-
servicers serviced any portion of this mortgage account? If the answer is yes,
give details of the names and addresses of each and every individual, party,
bank, trust or entity that has sub-serviced this mortgage account.

25. Has this mortgage account been made a part of any mortgage pool since the
inception of this loan? If yes, give details of each and every account mortgage
 pool that this mortgage has been a part of from the inception of this account to
the present date.

26. Whether each and every assignment of Andrea Davilar’s asset/monetary

instrument been recorded in the county land records where the property
associated with this mortgage account is located?

27. State whether there has been any electronic assignment of this mortgage with
MERS or any other computer mortgage registry service or computer program?
If yes, give details of the name and address of each and every individual,
entity, party, bank, trust or organization or servicers that have been assigned to
mortgage servicing rights to this account as well as the beneficial interest to
the payments of principal and interest on this loan.

28. Have there been any investors (as defined by Option One Mortgage
Corporation) who have participated in any mortgage-backed security,
collateral mortgage obligation or other mortgage security instrument that this
mortgage account has ever been a part of from the inception of this account to
the present date? If yes, give details of the name and address of each and every
individual, entity, organization and/or trust.

29. Give details of the parties and their addresses to all sales contracts, servicing
agreements, assignments, allonges, transfers, indemnification agreements,
recourse agreements and any agreement related to this account from the
inception of this account to the present date.
30. State how much amount was paid for this individual mortgage account by
Option One Mortgage Corporation?

31. If part of a mortgage pool, state the principal balance used by Option One
Mortgage Corporation to determine payment for this individual mortgage
loan?

32. If part of a mortgage pool, state the percentage paid by Option One Mortgage
Corporation of the principal balance above used to determine purchase of this
individual mortgage loan?

33. To whom did Option One Mortgage Corporation issue a check or payment to
for this mortgage loan?

34. Did any investor approve of the foreclosure of Andrea Davilers property?
State Yes or No.

35. Give details of all persons who approved the foreclosure of the property of
Andrea Daviler?

36. Have attorney fees ever been assessed to this account from the inception of
this account to the present date? State Yes or No.
37. If yes, detail each separate assessment, charge and collection of attorney fees
to this account from the inception of this account to the present date and the
date of such assessments to this account.

38. Have attorney fees ever been charged to this account from the inception of this
account to the present date? State Yes or No.

39. If yes, detail each separate charge of attorney fees to this account from the
inception of this account to the present date and the date of such assessments
to this account.

40. Have attorney fees ever been collected from this account from the inception of
this account to the present date? State Yes or No.

41. If yes, detail each separate collection of attorney fees to this account from the
inception of this account to the present date and the date of such assessments
to this account.

42. Give details of the name and address of each attorney or law firm that has
been paid any fees or expenses related to this account from the inception of
this account to the present date.

43. Specify in writing the provision, paragraph, section or sentence of any

Promissory Note, mortgage, deed of trust or any agreement signed by Andrea
Daviler that authorized the assessment, charge or collection of attorney fees.
44. Give details of each separate attorney fee assessed from this account and for
which each corresponding payment period or month such fee was assessed
from the inception of this account to the present date.

45. Give details of each separate attorney fee collected from this account and for
which each corresponding payment period or month such fee was collected
from the inception of this account to the present date.

46. Give details of any adjustments in attorney fees assessed and on what date
such adjustment was made and the reason for such adjustment.

47. Give details of any adjustments in attorney fees collected and on what date
such adjustment was made and the reason for such adjustment.

48. Has interest been charged on any attorney fees assessed or charged to this
account? State Yes or No.

49. Is interest allowed to be assessed or charged on attorney fees charged or

assessed to this account? State Yes or No.

50. How much total in attorney fees have been assessed to this account from the
inception to the present date?
51. How much total in attorney fees have been collected from this account from
the inception to the present date?

52. How much total in attorney fees have been charged to this account from the
inception to the present date?

53. Has there been any suspense or unapplied account transactions on this account
from the inception of this account until the present date? State Yes or No.

54. If yes, explain the reason for each and every suspense transaction that
occurred on this account. If no, please skip the questions in this section
dealing with suspense and unapplied accounts.

55. In a spreadsheet or in letter form in a columnar format, give details of each

and every suspense or unapplied transaction, both debits and credits that has
occurred on this account from the inception of this account to the present date.

56. Have you reported the collection of late fees on this account as interest in any
statement to Andrea Davilar or to the IRS? State Yes or No.

57. Has any previous servicers or sub-servicers of this mortgage reported the
collection of late fees on this account as interest in any statement to me or to
the IRS? State Yes or No.
58. Do you consider the payment of late fees as liquidated damages to you for not
receiving payment on time? State Yes or No.

59. Are late fees considered as interest? State Yes or No.

60. Give details of the expenses and damages Option One Mortgage Corporation
incurred for any payment Andrea Davilar made that was late.

61. Were any of these expenses or damages charged or assessed to this account in
any other way? State Yes or No.

62. If yes, describe what expenses or damages were charged or assessed to this
account.

63. Give details of the expenses you or others undertook due to any late payment
Andrea Davilar made.

64. Give details of the damages you or others undertook due to any late payment
Andrea Davilar made.

65. Give details of the provision, paragraph, section or sentence of any Note,
mortgage, deed of trust or any agreement Andrea Davilar signed that
authorized the assessment or collection of late fees.
66. Give details and list of each separate late fee assessed to this account and for
which corresponding payment period or month such late fee was assessed
from the inception of this account to the present date.

67. Give details and list of each separate late fee collected from this account and
for which corresponding payment period or month such late fee was collected
from the inception of this account to the present date.

68. Give details and list of any adjustments in late fees assessed and on what date
such adjustment was made and the reason for such adjustment.

69. State whether any interest has been charged on any late fee assessed or
charged to this account?

70. State whether any interest is allowed to be assessed or charged on the late fees
to this account?

71. State whether any late charges been assessed to this account?

72. If yes, how much in total late charges have been assessed to this account from
the inception of this account to the present date?
73. Give details with the exact months or payment dates Option One Mortgage
Corporation or other previous servicers or sub-servicers of this account claim
which Andrea Davilar have been late with a payment from the inception of
this account to the present date.

74. State whether any late charges been collected on this account from the
inception of this account to the present date?

75. If yes, how much in total late charges have been collected on this account
from the inception of this account to the present date?

76. State whether Wells Fargo National Association as trustee has ever been
assigned in blanks the mortgage and note after closing.

77. Pursuant to a pooling and servicing agreement has Wells Fargo National
Association as trustee been assigned all rights and title to subject mortgage
and note and if so when did this event take place.

Executed this day of , 2008.

Name and title of the authorized officer or the agent

OPTION ONE MORTGAGE CORPORATION

State of:

County of:

Before me the undersigned, a Notary Public in and for the said County and State on
this day of , 2008, personally appeared, who
is ( ) personally known to me or ( ) proven by proper identification, to be the person
who executed the within and foregoing instrument.

Type of ID:

Signature

Notary Public (seal)

Request for Discovery prepared and submitted by:

Andrea Daviler

Mailing address:
 Certificate of Service

I, Andrea Daviler, certify that on day of December 2008, a true and

correct copy hereof was served upon the attorney for the Plaintiff by both certified
mail and facsimile transmission to:

Andrea Daviler