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IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

OF FLORIDA, IN AND FOR BREVARD COUNTY

CHASE HOME FINANCE LLC, Case No.: 05-2009-CA-74735-XXXX-XX

Plaintiff,
v.

THOMAS A. WEBSTER, et al

Defendant, Pro Se
____________________________________________/

Notice of Filing

Defendant, Thomas A. Webster, Pro Se, hereby gives notice to the Court of Defendant’s First
Request for Production of document to Plaintiff.

Respectfully submitted on this 4th day of March 2010

_____________________________________________
Thomas A. Webster
4655 Elena Way
Melbourne, FL 32934

Certificate of Service
I Thomas A. Webster certify that on the 4th day of March 2010, a true and correct copy of
Hereof was served upon the Attorney for the Plaintiff by mail to:

Ashleigh L. Politano, Esq.


Florida Default Law Group, P.L.,
9119 Corporate Lake Drive Suite 300
Tampa, Florida 33634

______________________________________

Thomas A. Webster, Defendant, Pro Se

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IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
OF FLORIDA, IN AND FOR BREVARD COUNTY

CHASE HOME FINANCE LLC, Case No.: 05-2009-CA-74735-XXXX-XX

Plaintiff,
v.

THOMAS A. WEBSTER, et al

Defendant, Pro Se
____________________________________________/

DEFENDANT’S FIRST REQUEST FOR PRODUCTION

COMES NOW, Thomas A. Webster, Defendant, Pro Se, and pursuant to 1.280 and 1.350 of
Florida Ruled of Civil Procedure hereby propounds this First Request for Production to
Plaintiff. Plaintiff shall respond to this request in the manner and within the time frame
prescribed by rule 1.350.
Definitions
For Purpose of this request, the following definitions apply:
1. All capitalized terms in this Request shall have the same meaning attributed to such terms
in the Complaint.
2. “All Documents” means any document known to you and every such document which can be
located by you or your representative or discovered by reasonably diligent efforts.
3. “And” and “or” shall be construed in the disjunctive or conjunctive as necessary to make
the request inclusive rather than exclusive.
4. “Communication” shall mean any oral or written utterance, notation or statement of any
nature whatsoever, by and whomever made, including but not limited to correspondence,
conversations, dialogues, discussions, interviews, meetings, consultations, agreements and
other understandings between or among two or more persons.
5. “Complaint” refers to the Complaint filed by plaintiff in this action.

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6. “Defendant” refers to Thomas A. Webster and any of his agents, representatives or other
persons acting or purporting to act on his behalf.
7. “Document” means the original and all copies whether different from the original by
reason of any notation made on such copies or otherwise, regardless of the origin or location,
of any written, recorded, transcribed, punched, taped, filmed, electronically or digitally stored,
or graphic matter, however produced or reproduced, including but not limited to, all physical
forms of correspondence, e-mails including any and all email attachments, facsimiles,
accounts payable records, accounts receivable records, agreements, audio recordings (whether
transcribed or not), balance sheets, bills, books, books of accounts, cablegrams, cash receipt
journals, cash disbursement journals, certificates, charters, charts, checks, communications,
correspondence, compilations, computer cards, computer printouts, computer programs,
computer readouts, computer disks, data compilations, diaries, disks and diskettes, drafts,
drafts of documents, emails (whether printed out or not) to include any and all email
attachments, entries, estimates, expense reports, financial analysis, financial books, financial
records, financial statements, general ledgers, income statements, intra-office and inter-office
communications, invoices, itemizations, journals, letters, manuals memoranda of all
conversations of telephone calls, minutes, notes, orders, photocopies, press releases,
publications, receipts, recordings, records, records of account, reports, resolutions, sketches,
specifications, statements, statistical records, studies, summaries, tapes, telegrams, texts,
writings or work papers which are in the possession, custody or control of Plaintiff’s or your
representatives. In all cases where documents are in a language other than English, all
translations and materials related to each and every transaction of such documents shall also
be considered to be documents.
8. “Including” shall mean without limitation.
9. “Person” means any natural individual acting in any capacity whatsoever, or any entity or
organization, including the organization’s divisions, departments or other units. The term
“person” shall include but not limited to, a public or private corporation, partnership, joint
venture, voluntary or unincorporated association, organization, proprietorship, trust, state
governmental agency, commission, bureau, or department.

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10. “Plaintiff” refers to the above captioned Plaintiff, and any of his agents, representatives or
other persons acting or purporting to act on its behalf, and includes any of his members,
trustees, beneficiaries, past and present, predecessors and successors in interest.
11. “Relating to” or “relates to” means pertaining to, referring to concerning, supporting, or
refuting.
12. “Representative” means any and all agents, employees, servants, attorneys or other person
acting or purporting to act on behalf of the person in question.
13. “You,” “Your” or “Yourself” refers to plaintiff to which these requests are addressed, as well
as any person acting or purporting to act on his behalf.
14. Reference to the singular in any of these requests shall also include a reference to the plural,
and references to the plural shall also include a reference to the singular.

INSTRUCTIONS

A. For documents no longer in the possession, custody or control of your representative, for any
reason with respect to each such document:
1. Describe the nature of the document
2. State the date of the document
3. Identify the persons who sent and received the original and copies of the document.
4. State in as much detail as possible the contents of the documents and;
5. State the manner and date of disposition of the document.

B. For any communication or document you claim to be protected by Attorney/Client privilege,


work-product doctrine, and/or other applicable privilege, please provide a list of all such
documents on or before the due date of this request, containing the following information of each
documents;
1. The identity of the speaker or author;
2. The identity of all persons who received or heard the document or communication;
3. The date of the communication or document;
4. The nature of the document or communication; and
5. The subject matter of the document or communication.
In addition, for each such communication or document, state the basis of your claim of privilege
or work product.

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C. If you cannot produce any of the documents in full, produce to the extent possible and specify in
writing the reasons for your inability to produce the remainder of the documents.

D. After the date of your initial production of responsive documents, if additional responsive
documents come into your possession, custody, or control, such additional responsive documents
shall be produced to the undersigned counsel immediately.

FIRST REQUEST FOR PRODUCTION TO PLAINTIFF

1. All correspondence, letters, memoranda, telephone messages, telephone memoranda, telephone


logs, notes, or other documents evidencing any and all communications between Plaintiff and
Defendant.

2. All documents contained in the Loan Original File including but not limited to:

a. All Documents related to Plaintiff’s qualification or approval of defendants for


subject loan,
b. All documents submitted to Plaintiff by any loan originator, mortgage broker,
correspondent lender and/ or mortgage lender,
c. All documents including those related to Plaintiff’s processing of the subject loan
for closing and funding and
d. All documents related to the closing and funding of the loan on subject property.

3. All correspondence, letters, memoranda, agreements, telephone messages, telephone memoranda,


telephone logs, notes, or other documents evidencing any and all communications between
Plaintiff and loan originator, mortgage broker, correspondent lender and/or mortgage lender.

4. All Correspondence, letters, memoranda, telephone messages, telephone memoranda, telephone


logs, notes, or other documents evidencing any and all communications between Plaintiff and
the settlement/closing agent, including without limitation copies of all disbursement checks.

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5. All disclosures provided to the Defendant required by State and Federal Law, including but not
limited to those required by the Truth in Lending Act, the Real Estate Settlement Procedures Act
and the National Housing Act.

6. All documents relating to any and all payments by Defendant to Plaintiff, on Defendant’s behalf to
Plaintiff, or by Plaintiff on behalf of Defendant, including but not limited to:
a. Payment history on the subject loan from its inception to present, including all
debits and credits and
b. Payment history on any and all escrow accounts associated with the subject loan
from its inception to present, including all debits and credits.

7. All documents in Plaintiff’s possession or available to Plaintiff that establish the Plaintiff’s
standing to bring this foreclosure action, including but not limited to:
a. Copies of all contracts, documents, agreements and other disclosure forms, written
communications, notes, memoranda and records concerning the note and mortgage that are subject
of this action including attorney fee contracts.
b. Copies of all receipts for payments made by or to and/or received by the Plaintiff concerning the
note and mortgage that are the subject of this foreclosure action.

8. All documents in the Plaintiff’s possession or available to the Plaintiff that establish the Plaintiff
as the legal, beneficial or equitable owner of the promissory note that is the subject of this
foreclosure action.

9. All documents in the Plaintiff’s possession or available to Plaintiff that establish the Plaintiff is the
servicer of the loan that is the subject of this foreclosure action.

10. All documents in the Plaintiff’s possession or available to Plaintiff that identify what entity or
entities are the beneficial owner of the subject promissory note that is the subject of this
foreclosure action.

11. Copies of any communications and/or documents evidencing instructions and/or directions that the
Plaintiff has received concerning the filing of this foreclosure action.

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12. All documents evidencing the manner in which the Plaintiff recorded transfer of the subject note
on its general ledger.

13. Produce all documents that evidence that the Plaintiff suffered damages as a result of the alleged
default described in the complaint.

14. Produce all documents presented to the Plaintiff prior to the Plaintiff accepting transfer of the
subject note from the transferor.

15. Produce all documents that evidence any value given to the transferor by the Plaintiff in exchange
for the transfer of the subject note.

16. Produce all documents that evidence the manner in which the Plaintiff recorded the transfer of the
subject note on its United States Federal Tax Returns.

17. Produce all documents evidencing the funds loaned to this Defendant by the original payee on the
note.

18. Produce any and all documents evidencing any credit default swap that provides for a payment to
be made in the event of Defendant’s default on the subject note.

19. All documents relating to any sale, assignment, pledge and/or hypothecation of the mortgage note.

20. All documents which evidence Plaintiff’s status as owner and holder in due course of the subject
mortgage and note.
CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been furnished by U.S. Mail, this
4th day of March, 2010 to:

Ashleigh L. Politano, Esq.

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Florida Default Law Group, P.L.,
9119 Corporate Lake Drive Suite 300
Tampa, Florida 33634
March 4, 2010

______________________
Thomas A. Webster
Defendant, Pro Se
4655 Elena Way
Melbourne, FL 32934