Home - Foreclosure Defense - Pleadings Main Index
Notice of Interrogatories to Plaintiff
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
WELLS FARGO BANK, N.A.
CASE NO: 09-00xxxx-CA-(13)
A.M and M.A., et. al.
DEFENDANTS’, A.M and M.A., NOTICE OF SERVICE OF INTERROGATORIES TO PLAINTIFF
The Defendants, A.M and M.A., pursuant to Rule 1.340, Fla. R. Civ. P., hereby files this Notice of Service of Interrogatories propounded to Plaintiff, WELLS FARGO BANK, NA.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that on September 28, 2012, a true and correct copy of the foregoing was Fax: 813.251.1541; E-Mail:
to: Ron Pereira, Esq., Ronald R. Wolfe & Associates, P.L , Esq., 4919 Memorial Hwy, Ste 200, Tampa, Florida 33634-7500.
SACKRIN & TOLCHINSKY, P.A.
Attorney for Defendant(s)
2100 E. Hallandale Bch Blvd./Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 458-8655
Facsimile: (954) 455-9649
ALAN D. SACKRIN, ESQ. Florida Bar No. 349070
LARRY TOLCHINSKY, ESQ. Florida Bar No 021997
INTERROGATORIES TO PLAINTIFF, WELLS FARGO BANK, NA
1. Please state the name and address of the person answering these interrogatories and that person’s relationship to the Plaintiff, Well’s Fargo Bank, NA.
2. Defendants served the following Request for Admission on Plaintiff on this date: “It is Plaintiff’s contention in this lawsuit that the sole reason that the most recent proposed HAMP modification (made after December, 2010 mediation) was denied or rejected by Plaintiff due to the existence of the HELOC loan from Bank of America on the subject property.” If Plaintiff denied this Request for Admission, please state the factual basis for the denial.
3. Please state the names, last known residences and addresses of Plaintiff’s employees and agents who have knowledge concerning the answer to number 2, above, and please state the knowledge possessed by each person and the relationship to that person.
4. Please identify all documents sent to Defendants or Defendants’ attorneys which explains the reason for the purported denial of the subject HAMP modification and please produce any such documents with the answer to these interrogatories.
5. Please itemize by date the amounts paid, if any, by Plaintiff for property taxes and insurance on the subject property. State what each payment represented.
WELLS FARGO BANK, NA
STATE OF )
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared ____________________, a representative of Wells Fargo Bank, NA, who, after being first by me duly sworn, deposes and states that she/he is the person described in and who executed the attached or foregoing instrument, and she/he acknowledged before me that the facts contained therein are true and correct.
WITNESS my hand and official seal at the State and County aforesaid, this _____ day of __________, 20_____.
PERSONALLY KNOWN ____ OR;
PRODUCED IDENTIFICATION: ________________________________________
TYPE OF IDENTIFICATION PRODUCED
NOTARY PUBLIC, State of
PRINTED NAME OF NOTARY PUBLIC
My Commission Expires:
This is a sample document related to a specific set of facts and circumstances and should not be used or relied upon if any foreclosure, deficiency judgment, short sale or any other real estate matter. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique.