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Request for Production to Plaintiff

IN THE CIRCUIT COURT OF THE
20TH JUDICIAL CIRCUIT IN AND
FOR COLLIER COUNTY, FLORIDA

DEUTSHCE BANK NATIONAL TRUST CASE NO: 07-xxxx-CA
COMPANY, AS TRUSTEE FOR MORGAN
STANLEY ABS CAPITALI, INC., TRUST
2006-HE6, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2006-HE6,
Plaintiff,
vs.
D.O.
et. al.,
Defendant.
__________________________________/

DEFENDANTS REQUEST FOR PRODUCTION TO PLAINTIFF

The Defendants, D.O., by and through their undersigned attorney and requests the Plaintiff, DEUTSHCE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN, STANLEY ABS CAPITALI, INC., TRUST, 2006-HE6, MORTGAGE PASS-THROUGH, CERTIFICATES, SERIES 2006-HE6, to produce, pursuant to Fla.R.Civ.P. 1.350 to the Law Office of Alan D. Sackrin, the following:

1. All documents which Mohit Pathen, Vice President of Countrywide Home Loans Servicing, LP, reviewed or relied upon in preparing and/or signing the affidavit in support of Plaintiff’s Motion for Summary Judgment (Exhibit “A” to Plaintiff’s Motion for Summary Judgment). 

2. The original promissory purportedly executed by Defendants, D.O., pertaining to this foreclosure action.

3. Any properly executed Assignments of the Mortgage and Promissory Note pertaining to this foreclosure action. 

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on March 26, 2010, a true and correct copy of the foregoing was faxed, emailed and mailed to: Michael J. Alterman, Esq., Law Office of David J. Stern, P.A., 900 S. Pine Island Road, Suite 400, Plantation, FL 33324-3920 [Attorneys for Plaintiff]; David E. Leigh, Esq., 5150 Tamiami Trail, North, Suite 501, Naples, FL 34103 [Attorney for Sherwood V., Inc.] and David Brian Levin, Esq., Adorno & Yoss LLP, 2525 Ponce de Leon Blvd Ste 400, Miami, Florida 33134-6044.

Attorney for Defendants
2100 East Hallandale Beach Blvd./Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649

By__________________________________________
ALAN D. SACKRIN, ESQ. Florida Bar No. 349070
LARRY TOLCHINSKY, ESQ. Florida Bar No 021997

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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.