IN THE CIRCUIT COURT IN AND FOR _______________COUNTY, FLORIDA _(Bank)_______________________ _____________________________ _____________________________, Plaintiff, vs. __(Defendant(s))__________, Defendant(s).

____________________________/ DEFENDANT'S FIRST REQUEST FOR PRODUCTION Defendant(s), pursuant to Fla.R.Civ.P. 1.350, hereby request that Plaintiff produce and permit and serve its answers to _____(your name and address)________ within thirty (30) days of the service of this request. INSTRUCTIONS A. This request includes all documents that are in the Plaintiffs possession, CASE NO.: _____________________

CIVIL DIVISION

Custody, or control, regardless of where they are located. B. Plaintiff is required to provide all relevant information, regardless of whether

there has been a change in any or all of the corporate Plaintiffs names, as such a name change does not absolve the entitys obligation to comply with this request. C. This request covers documents in the Plaintiffs possession, custody, or

Control including documents maintained at any of the Plaintiffs present or former offices, residences, attorneys offices, or elsewhere, that are or were created during, or concerning the period from the date of alleged execution of the note and mortgage to the present.

D.

In addition to originals and final versions of documents, as well as all copies,

non-identical to the original in any respect, including any copy bearing non-identical markings or notations of any kind. If any document existed in different forms at different times, both the current version and all prior versions are to be separately produced. E. All responsive documents are to be produced, whether the information therein

is final, preliminary, interim, draft, actual, estimated, audited, unaudited, formal or informal, or is a prediction, forecast, projection, or opinion. F. All documents that exist in digital form, including databases, spreadsheets,

email messages or attachments, word processing files, and document image files, are to be produced in their native digital file format on CD, DVD, or commonly used portable format, along with the software necessary to read, search, sort, organize, and print the contents of the documents, unless such software is commonly available. G. If objection is made to any of these requests, state whether any documents

are being withheld from inspection and production on the basis of such objection or whether inspection and production or responsive documents will occur notwithstanding such objection. H. If any claim or privilege or work product protection, whether based on statute,

rule, or otherwise, is asserted as a ground for not producing any document, describe, with respect to each document for which privilege or work product protection is claimed, the nature of the documents, communications, or things not produced or disclosed in a manner that will enable plaintiffs to assess the applicability of the privilege or protection asserted and set forth the asserted ground for not producing such document.

I.

Any request that is subject to an objection of privilege or work product

protection but which nevertheless contains non-objectionable information that is responsive to this request must be produced, but that portion of the document for which the objection is asserted may be redacted, provided that the document is marked redacted and provided further that the above requested information is furnished. J. If any document responsive to this request was at one time, but no longer is,

in existence, please so state and, for each such document state: (1) The type of document; (2) Its date (or approximate date); (3) Its author, sender, and/or addresses; (4) The date on which it ceased to exist; (5) Its subject; (6) The type of information it contained; (7) The circumstances under which it ceased to exist; and (8) The identify of all persons with knowledge of the contents of such document. K. In the event that a document responsive to this request has been removed

from the Plaintiffs files prior to production on grounds other than privilege, with respect to each such document, set forth the reason for its removal and describe the document in a manner that will enable defendants to assess the basis for its removal.

REQUEST FOR PRODUCTION

1.

A copy of all documents which create the trustee relationship by, between, or otherwise relating to ___(insert Plaintiffs name)_______, if applicable, Mortgage Electronic Registration Systems, Inc. Produce the original Mortgage/Deed of Trust and Note for inspection and copying at, The 200 Building, Suite 701, 200 SE 1st ST, Miami, Florida 33131. A copy of all documents which create the successor relationship by, between, or otherwise relating to ___(insert Plaintiffs name)_______and Mortgage Electronic Registration Systems, Inc. that demonstrates the Plaintiff has standing to bring this Complaint in Foreclosure. A copy of all documents which create the nominee relationship by, between, or otherwise relating to ___(insert Plaintiffs name)_______and Mortgage Registration Systems, Inc. that demonstrates the Plaintiff has standing to bring this Complaint in Foreclosure.

2.

3.

4.

5. A copy of the documents that are relied upon by the Plaintiff to demonstrate who is defined as the Lender by the Mortgage.
6.

If the Lender is no longer MERS a copy of the documents demonstrating who is now the Lender.

7. A copy of the document(s) that reference the Defendant or his account and any second mortgage holder which are directly or indirectly in control of the Plaintiff and that are not protected by attorney-client privilege.
8.

A copy of all document(s) referencing ___(insert Plaintiffs name)_______the Defendant or her account under the control of the Plaintiff that are not protected by attorney-client privilege.

9. A copy of all document(s) that are relied upon by the Plaintiff to demonstrate the Plaintiff has standing to bring and maintain this lawsuit. 10. A copy of all documents that are relied upon by the Plaintiff to demonstrate that MERS is an agent of the Plaintiff in respect to the Mortgage and Note. 11. A copy of any and all documents the Plaintiff intends to rely upon at trial that have not already been provided to the Defendant. 12. Any document referred to by the Plaintiff in preparation to respond to Defendant(s) posed interrogatories.
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13. Each and every document and/or communication that supports Plaintiffs claim that Defendant(s) is in default under a loan with the Plaintiff. 14. Each and every document and/or communication between Plaintiff and any defendant relating to the loan subject to this complaint. 15. A copy of documents provided to the Defendant at the time of application through closing, including all Truth in Lending Act (TILA) and RESPA disclosures. 16. Provide any assignments or conveyances or mortgage/deed of trust and transferring the mortgage and note from immediate predecessor-in-interest of the Mortgage/Deed of Trust and note to the Plaintiff, including any and all recorded copies. 17. Provide any assignments or conveyances of the note transferring the mortgage and note from immediate predecessor-in-interest of the Mortgage/Deed of Trust and Note to the plaintiff. 18. Provide copies of all changes to note under Plaintiffs control for the mortgage and note subject to this lawsuit. 19. Provide copies of all assignments or conveyances of mortgage under Plaintiffs control for the mortgage and note subject to this lawsuit.
20.

If the chain of title does not provide the entire ownership of the note and mortgage uninterrupted, provide the documents, which demonstrate the uninterrupted ownership of the note and mortgage from closing until today. Provide the documents, as defined above, in the possession of the Plaintiff, which reference the Defendant or his account. Provide the documents that include memos, notes and correspondence in the possession of Mortgage Electronic Registration Systems, ___(insert Plaintiffs name)_______which reference the defendant or her account which have not been provided as of yet.

21.

22.

23. Each and every document that supports the amount of damages Plaintiff claims it has suffered as a result of any purported default of the loan by Defendant.
24.

Copies of Defendant(s) payment history.

25. A complete copy of the loan history from the date of inception to the date of this request. This request includes a glossary for all terms and symbols such that the loan history is understandable to any person.
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26. A copy of any and all documents necessary to establish that Plaintiff is owner of said mortgage at issue in this complaint. 27. A copy of Plaintiffs Mortgage Application. 28. A copy of Plaintiffs closing statement. 29. A copy of Defendant(s) mortgage commitment provided to Plaintiff. 30. Copies of any and all complaints to Lender and assignee about problems similar to borrowers complaints alleged in her affirmative defenses to Plaintiffs Complaint.
31.

Copies of Articles of Incorporation for ___(insert Plaintiffs name)_______and Mortgage Electronic Registration Systems, Inc.

32. A complete copy of any and all contracts or agreements with any person or entity involved in this loan including but not limited to any mortgage broker and or appraiser. 33. A copy of all documents reflecting, evidencing, or establishing in any way the value of the property that is the subject of the mortgage in this case including but not limited to any and all appraisals, broker price opinions, or property inspections. 34. Produce a complete copy of the loan file including the inside and outside covers of the file. 35. Produce a complete copy of the foreclosure file including the inside and outside covers of the file. 36. A complete copy of the pooling and servicing agreement. 37. A complete copy of all documents evidencing, reflecting, or establishing any and all efforts to engage in foreclosure prevention or workout measures including but not limited to notices, phone logs, correspondence, email records (internal as well as external to your operations), memos, and any other documents. This request includes any documents reflecting on decisions and the basis of those decisions to grant or deny any assistance or relief.

CERTIFICATE OF SERVICE I CERTIFY that the DEFENDANTS FIRST REQUEST FOR PRODUCTION, was served by REGULAR MAIL on the attorneys of record/interested parties in this action: _(law firm name and address)____________on this _(day)_ day of _(month)_, 201_.

_(signature)___________ (Print name) (address) (phone number)