3. Interrogatories YOU ARE REQUIRED, pursuant to Florida Rule of Civil Procedure rules 1.280 and 1.

340, by and through an authorized officer of your company, to answer completely, in writing, and under oath, the following Interrogatories, and to return your answers to these Interrogatories to Samuel Clay Adams at his mailing address indicated below, within thirty days of the date of service of these Interrogatories. Instructions to Interrogatories 1. These interrogatories are directed toward all information known or available to plaintiff

WELLS FARGO BANK, N.A., including information contained in the records and documents in WELLS FARGO BANK, N.A.'s custody or control or available to WELLS FARGO BANK, N.A. upon reasonable inquiry. 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 WELLS FARGO BANK, N.A. obtains or becomes aware of any further information pertaining to that interrogatory, the authorized officer for WELLS FARGO BANK, N.A. is requested to serve a supplemental answer setting forth such information. Definitions 1. "You" and "your" include WELLS FARGO BANK, N.A. and any and all persons acting for or in concert with WELLS FARGO BANK, N.A. 2. 3. "Document" includes every piece of paper held in your possession or generated by you. "Samuel Clay Adams" includes all nick names, pseudonyms and/or misnomers in any papers or documents referencing the defendant or any liability or obligation attributable to him, including Sam Adams, Samuel Adams, Samuel C. Adams, SAMUEL ADAMS, SAMUEL C. ADAMS, and/or SAMUEL CLAY ADAMS.

First Request for Discovery - page 7 of 11

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 WELLS FARGO BANK, N.A is, and name every

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

3.

State the name, job title, and business address of each person who has first hand personal

knowledge of the time and/or circumstances under which the promissory note obligating Samuel Clay Adams and/or alienable in this instant case was lost or destroyed as alleged in the complaint.

First Request for Discovery - page 8 of 11

4.

State the names of all persons or entities, in order of assignment, who at any time were

constructive holders or holders in due course of the promissory note obligating Samuel Clay Adams and/or alienable in this instant case prior to its alleged assignment to WELLS FARGO BANK,N.A.

5.

Explain why the alleged copy of the promissory note submitted as "Exhibit A" attached

to the named plaintiffs complaint includes no allonge showing any assignment of the note to named plaintiffWELLS FARGO BANK, N.A.

6.

Describe in detail when, where and how the promissory note obligating Samuel Clay

Adams and/or alienable in this instant case came to be lost or destroyed as alleged in the complaint. 7. If named plaintiff WELLS FARGO BANK, N.A. did not keep or cannot produce a copy

of an allonge or other paper showing assignment to WELLS FARGO BANK, N.A of the promissory note obligating Samuel Clay Adams and/or alienable in this instant case, explain why.

First Request for Discovery - page 9 of 11