Motion To Compel Further Discovery Responses From Fannie Mae

Perry v. JPMorgan Chase Bank N.A.
et al
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Page 1 of 2 vs. JP MORGAN CHASE BANK N.A.; CHASE HOME FINANCE LLC; FEDERAL NATIONAL MORTGAGE ASSOCIATION; QUALITY LOAN SERVICE CORP.; and all persons unknown, claiming any legal or equitable right, title estate, lien or interest in the property described in this Complaint adverse to Plaintiffs title thereto and as DOES 1-100, Inclusive, Defendants Leighton Lee PERRY, Plaintiff, Plaintiff pro se LEIGHTON LEE PERRY
Case # MSC10-02914
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA Case No.: No. MSC10-02914 NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FURTHER RESPONSES TO INTERROGATORIES TO FEDERAL NATIONAL MORTGAGE ASSOCIATION (SET TWO) REQUEST FOR MONETARY SANCTIONS MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF LEIGHTON LEE PERRY; SEPARATE STATEMENTS; Judge: Hon. Dept: 31 Date: February 28, 2013
9:30 a.m.
To Federal National Mortgage Association (FNMA) and AlvaradoSmith, APC, attorney of record for FNMA: PLEASE TAKE NOTICE that at 9:30 AM, on February __28_ , 2013, or as soon thereafter as the matter may be heard, in Dept. 31 of the Contra Costa County Superior Court, 785 Court St., Martinez, California, Plaintiff Leighton Lee Perry will move the Court for an order compelling Defendant FNMA to respond to and produce, without objections, SET TWO of Plaintiffs Form and Special Interrogatories and Request to Produce Documents, and impose monetary sanctions against Federal National Mortgage
Notice and Motion to Compel Further Discovery Defendant FNMA. SET TWO
Perry v. JPMorgan Chase Bank N.A. et al

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Association (FNMA) in the amount of no less than $267 for its persistent and wrongful obstruction of discovery and lack of verification as referenced in the Declaration of Plaintiff Leighton Lee Perry. This motion is made pursuant to the California Code of Civil Procedures 2030.300, 20301.310, and 2033.290 on the following grounds: 1. That Respondent has violated the negotiate in good faith relationship between parties and directive to use discovery as a tool to reduce court resources by pleading numerous boiler plate junk objections to highly relevant requests for production of documents and Form and Special interrogatories with such insufficiency and evasion as to cast doubt as to the merits of their actions. 2. That Respondent has failed to serve a timely response pursuant to Cal. Code of Civil Proc 2030.290(b) to Plaintiffs Form and Special Interrogatories, and to Requests for Production of Documents served upon FNMA. Efforts at meet and confer have been fruitless, allowing the Court to award sanctions in the form of waivers to further objections by Respondents for failing to verify their responses. 3. That Respondent has failed to seek a protective order within the 30 days allotted by 2030(h) of the Code of Civil Procedure despite raising general objections citing privilege, confidentiality, or work product in lieu of identifying documents with particularity and objection. This motion will be based on the notice of motion, the attached memorandum of points and authorities, attached exhibits, the Statements in Support of Motion to Compel, the record and files of this case, and any further oral or documentary evidence introduced at the hearing of this motion.
Dated: April 13, 2013 ___________________ LEIGHTON LEE PERRY Plaintiff pro se
Notice and Motion to Compel Further Discovery Defendant FNMA. SET TWO

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MEMORANDUM OF POINTS AND AUTHORITIES I. STATEMENT OF FACTS On or about November 11, 2012, Plaintiff served his set of discovery on Defendant Federal National Mortgage Association (FNMA) [see Exhibit A]. On December 7, 2012, Plaintiff stipulated to an extension request to December 31, 2012, received by David Chavez in an email with correspondence attached [Exhibit C]. On December 21, 2012, FNMA served Responses to Plaintiffs Request for Admissions by regular mail to Plaintiff. Plaintiff presented his concerns in follow-up email and correspondence which was discussed in a long phone call by parties. Subsequent emails were exchanged, primarily regarding the lack of verification by FNMA. As of the filing of this motion unmet promises by FNMAs counsel have left Plaintiff no choice but to file this motion to maintain his rights to discovery [Cal. Code Civ. Proc 2031.310(c)] . Plaintiff is authorized under California Code of Civil Procedure 2030.300, 2031.310, and 2033.290 to move to compel further responses. The conduct evidenced above is precisely the type of conduct that the discovery statutes are aimed at remedying, and accordingly, an order should issue compelling Defendant FNMA to immediately produce the requested information and documents. II. GOOD CAUSE EXISTS TO ORDER PRODUCTION OF THE REQUESTED DOCUMENTS FNMA objected to the production of numerous categories of documents requested in Plaintiffs SET
TWO. As fully set forth in the separate Statement filed concurrently herewith and the Declaration of Plaintiff attached hereto, the documents requested are either directly relevant to the subject matter of this action or are reasonably calculated to lead to the discovery of admissible evidence. The requested documents relate primarily to the history of Plaintiffs loan file. These original documents strike to the heart of the matter; whether FNMA has a beneficiary interest or security interest in Plaintiffs property and thereby might claim the right of a non-judicial foreclosure. The information Plaintiff seeks is not available from other sources, as the sole source of the documents and information is in FNMAs possession or control and not otherwise obtainable by Plaintiff. As a result, Plaintiff would be entirely unable to prosecute its underlying causes of action were these documents kept from his discovery efforts. Under such circumstances C.C.P. 2031.310 authorizes Plaintiff to compel the
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Points & Authorities for Motion to Compel Defendant FNMA. SET TWO

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production of such documents. Plaintiffs Statement addresses each of the boilerplate objections that FNMA presented to frustrate discovery. With few exceptions FNMA has objected with different variations of the junk objections that the request is overbroad, irrelevant, unduly burdensome, ill-constructed, vague, confidential / proprietary, or is ambiguous or unintelligible. Where there is no legitimate privilege issue or claim of attorney work product, the burden to show good cause for productions is met simply by a fact-specific showing of relevance. TBG Ins. Services Corp v. Superior Court, [96 Cal. App.4th 443, 448] (2002). Once that showing is made the burden shifts to the party opposing the production to justify the objection. Kirkland v. Superior Court, [95 Ca.App. 4th 92, 98] (2002); Person v. Farmers Ins. Group of Companies, [52 Cal.App. 4th 813, 818] (1997) in response to proper discovery request, burden is upon health care provider to establish that compilation of requested patient billing records would be unduly burdensome or oppressive. The fact that there is no alternative source for the information is an additional factor in determining good cause for production. See Associated Brewers Dist. Co. v. Superior Court, [65 Cal 2d 583, 587] (1967). GOOD CAUSE EXISTS TO ORDER FURTHER RESPONSES TO THE SPECIAL INTERROGATORIES Responding Party consistently uses the objections of overly broad, unduly burdensome,
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vague, ambiguous, and not relevant to issues raised in this action in the majority of their responses to Propounding Partys Request for Special Interrogatories. In Korea Data Systems Co. Ltd v Superior Court, [51 Cal App 4th at P. 1516] the court stated the use of boilerplate objections is improper; Coy v. Superior Court, [58 Cal App 2nd at pp 220-221] the burden falls upon the responding party to justify any objections or failure to fully RESPONSE discovery. Propounding Party submits that Respondent is the only source for the evidence of the power to sell Plaintiffs home through non-judicial means and is relying on Plaintiffs loan file to do so. Respondents objection to these requests for production of documents as seeking documents that are neither relevant nor reasonable calculated to lead the discovery of admissible evidence is without merit. In this action the information sought is relevant to 1) Defendants non-judicial foreclosure of Plaintiffs primary residence and 2) the enforceability of Plaintiffs promissory note and deed of trust as relied upon by Defendant to determine note holder not in due course of their beneficiary and security interests. Denying Plaintiff an
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opportunity to discover whether such efforts by Respondent was proper and Respondents meritless objections to Propounding Partys request for production of documents will result in unfair and irremediable harm to Plaintiff. Plaintiff would have the court note that no Verification to Responding Partys answers to his special interrogatories has been served to Propounding Party as of the filing of this motion. As such, Responding Party cannot claim legal rights of having responded to Propounding Partys interrogatories within statutory limits. Although a response composed of objections with a sprinkling of good faith responses was served, no verification accompanied it as required in Cal. Code of Civil Proc. 2030.210(a) The party to whom interrogatories have been propounded shall respond in writing under oath . MONETARY SANCTIONS SHOULD BE AWARDED AGAINST DEFENDANTS FOR OBSTRUCTING PLAINTIFFS DISCOVERY EFFORTS California Civ. Code Proc 2030.300(d) states
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The court shall impose a monetary sanction under Chapter 7 (commencing with 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. And Cal. Civ. Code Proc 2031.310(h) echos Except as provided in subdivision (j), the court shall impose a monetary sanction under Chapter 7 (commencing with 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response to a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. Monetary discovery sanctions include the reasonable expenses incurred by anyone as a result of that conduct. (C.C.P. 2023.020). Accordingly, Plaintiff seeks the imposition of sanctions against Defendant FNMA in an amount no less than $267. Plaintiffs expenses include
Filing fees Recorder fees Service costs Printing costs, including paper, toner, printer expense, printer maintenance Total
$90 30 65 72 $267
In light of the dramatic increase of the cost of filing motions to this court, the Courts recent denial to modify the terms of the preliminary injunction, and Defendants profusion of junk objections solely to
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cause economic disadvantage to Plaintiff, the Court should consider punitive sanctions by waiver of objections to further responses and such other issue sanctions as the Court may deem proper [CCP 2023.030], and further monetary awards. California Code of Civil Procedure 1008 provides (b) A party who originally made an application for an order which was refused in whole or part, or granted conditionally or on terms, may make a subsequent application for the same order upon new or different facts, circumstances, or law, in which case it shall be shown by affidavit what application was made before, when and to what judge, what order or decisions were made, and what new or different facts, circumstances, or law are claimed to be shown. For a failure to comply with this subdivision, any order made on a subsequent application may be revoked or set aside on ex parte motion. (c) If a court at any time determines that there has been a change of law that warrants it to reconsider a prior order it entered, it may do so on its own motion and enter a different order. By the time this motion is heard Plaintiff will have had to pay 3 months rent at $780 due to the unconscionable delay of Defendants. If the court considers Plaintiffs age of 65, a sanction for the delay may be trebled as a penalty for Elder Abuse [Cal. WIC Code 15610.30]. V. CONCLUSION The age old shysters legal advice goes something like if you dont have the facts, argue law. If you dont have the law, argue facts. If you dont have law or facts, argue rules. This court is now considering a motion that is only likely being made because the facts held solely by Defendants, if brought to light, would leave them defenseless against Plaintiffs allegations in this action. For example, responses to Plaintiffs special interrogatories state that his loan was not securitized. Yet Plaintiff cites a letter received from Chase Home Financial, LLC, stating that FNMA was the investor. For this reason, if for nothing else, Plaintiff requests the court issue an order: 1) compelling Defendant FNMA to provide answers to the special interrogatories as set forth in the separate Statement; (2) compelling Defendant FNMA to immediately produce the documents requested in the separate Statement; (3) imposing issue and monetary sanctions against Defendants in the amount of no less than $226. DATED: April 13, 2013
__________________________________ Leighton Lee Perry, Plaintiff pro se

1 2 3 4 5 6 7 8 9 10 Leighton Lee PERRY, 11 Plaintiff, 12 vs. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JP MORGAN CHASE BANK N.A.; CHASE HOME FINANCE LLC; FEDERAL NATIONAL MORTGAGE ASSOCIATION; QUALITY LOAN SERVICE CORP.; and all persons unknown, claiming any legal or equitable right, title estate, lien or interest in the property described in this Complaint adverse to Plaintiffs title thereto and as DOES 1-100, Inclusive, Defendants Plaintiff pro se LEIGHTON LEE PERRY
Case # MSC10-02914
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA Case No.: No. MSC10-02914 DECLARATION OF LEIGHTON L. PERRY IN SUPPORT OF PLAINTIFFS MOTION TO COMPEL RESPONSES TO DISCOVERY BY DEFENDANT FEDERAL NATIONAL MORTGAGE ASSOCIATION, ALONG WITH CONCURRENTLY FILED SEPARATE STATEMENTS
DECLARATION OF PLAINTIFF LEIGHTON LEE PERRY IN SUPPORT OF MOTION TO COMPEL On October 14, 2010, Plaintiff Leighton Lee Perry (Plaintiff) filed the instant action. Plaintiff makes a motion for order compelling Defendant Federal National Mortgage Association (FNMA) to respond to Request for Production of Documents and respond to Form and Special Interrogatories, and in support thereof declares as follows: 1. On or about July 25, 2011, Plaintiff served its first set of discovery on Defendant Federal National Mortgage Association (FNMA) [see Exhibit A]. 2. On August 29, 2011, FNMA served Responses to Plaintiffs Special Interrogatories and Responses to Plaintiffs Request For Production of Documents by regular mail to Plaintiff.
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Plaintiffs Declaration in Support of Motion to Compel Defendant FNMA. SET TWO

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3. On September 7, 2011, Defendants were absent from a Case Management Conference without prearranging for their absence. Plaintiff was thereby denied the opportunity to raise the issue of the status of discovery before the court. 4. On September 12, 2011, Plaintiff complied with the statutory meet and confer obligations by following up with FNMAs boilerplate objections in an email with Jenny L. Meredith of AlvaradoSmith, APC, in which parties agreed to extend time to allow response to a different set of discovery to another Defendant. 5. This was followed up by 2 phone calls made by Plaintiff on October 6, 2011 to Ms. Meredith, and a second call to her supervisor, S. Christopher Yoo. Both calls went unanswered and Plaintiff left messages regarding the topic of discovery and that they should call him back. 6. As of the filing of the motion on November 14, 2011, no return call had been made by Defendants. 7. On November 17, 2011 a hearing was held in Department 60 with parties present as a result of the tentative ruling stating parties should appear. At that hearing Commissioner Sanders determined that Plaintiff did not wait long enough to allow Defendants to reply and dismissed the motion after stating Plaintiff could re-submit the discovery by varying the questions somewhat. 8. A third discovery hearing was held in Department 60 on July 19, 2012, when Plaintiff filed a motion for a protective order for 80 requests of discovery filed by Defendants upon Plaintiff. Again, the tentative ruling of Commissioner Sanders was that both parties were to appear. At the hearing the attorney for Defendants conceded the requests were excessive, and parties agreed to further meet and confer and eventually resolved the discovery to parties satisfaction. 9. On November 13, 2012, Plaintiff served a second set of discovery (SET TWO) upon Defendant FNMA by overnight mail. The requests were modeled from requests served on Plaintiff by Defendant FNMAs counsel. 10. Defendants requested an extension to December 31, 2012, in correspondence dated December 7, 2012, to which Plaintiff stipulated. [Exhibit C] 11. Plaintiff was served with responses on December 21, 2012. The responses from Defendant FNMA were, and remain, not verified. 12. Defendants counsel has not determined a date for their amended responses in either
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correspondence, email, or in any telephone conversation. Defendants counsel still has failed to provide a privilege log for the documents upon which he raises those objections. Defendants counsel has yet to provide verification for FNMA even though Plaintiff has repeatedly offered to be served by email.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: April 13, 2013 __________________________ Leighton Lee Perry, Plaintiff pro se

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LIST OF EXHIBITS
EXHIBIT A Statements: Requests, Responses, and Objections for Form Interrogatories SET TWO EXHIBIT B Statements: Requests, Responses, and Objections for Special Interrogatories SET TWO EXHIBIT C Statements: Requests, Responses, and Objections for Production of Documents SET TWO EXHIBIT D Request for Production of Documents SET ONE EXHIBIT E Request for Special Interrogatories SET ONE EXHIBIT F Correspondence by FNMA of December 7, 2012, requesting extension

1 2 3 4 5 6 7 8 9 10 Leighton Lee PERRY, 11 Plaintiff, 12 vs. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JP MORGAN CHASE BANK N.A.; CHASE HOME FINANCE LLC; FEDERAL NATIONAL MORTGAGE ASSOCIATION; QUALITY LOAN SERVICE CORP.; and all persons unknown, claiming any legal or equitable right, title estate, lien or interest in the property described in this Complaint adverse to Plaintiffs title thereto and as DOES 1-100, Inclusive, Defendants Plaintiff pro se LEIGHTON LEE PERRY
Case # MSC10-02914
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA Case No.: No. MSC10-02914 STATEMENT IN SUPPORT OF MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES TO FEDERAL NATIONAL MORTGAGE ASSOCIATION (SET TWO)
STATEMENT IN SUPPORT OF MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES RESPONSES TO FORM INTERROGATORIES FORM INTERROGATORY NO. 2.11: At the time of the INCIDENT were you acting as an agent or employee for any PERSON? If so, state: (a) (b) the name, ADDRESS, and telephone number of that PERSON; and a description of your duties.
RESPONSE TO FORM INTERROGATORY NO. 2.11; (a) Yes

EXHIBIT A - Statements: Requests, Responses, and Objections for Form Interrogatories SET TWO
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(b)
Federal National Mortgage Association
OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 2.11: Propounding Party has a right to acquire knowledge sufficient to construct his case. FNMA as agent for defendant FNMA, requires further elaboration of its duties to, presumably, itself, particularly in the roles of trustee, master servicer, investor, beneficiary, underwriter. FORM INTERROGATORY NO. 3.1: Are you a corporation? If so, state: (a) the name stated in the current articles of incorporation; (b) all other names used by the company during the past 10 years and the date each was used; (c) the date and place of incorporation; (d) the ADDRESS of the principal place of business; and (e) whether you are qualified to do business in California. RESPONSE TO FORM INTERROGATORY NO. 3.1: No (a) N/A (b) N/A (c) N/A (d) N/A (e) N/A OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 3.1: Propounding Party has a right to acquire knowledge sufficient to construct his case. FNMA is described on its own website as a federally chartered corporation. No wonder FNMA refused to verify these responses. FORM INTERROGATORY NO. 4.1: At the time of the INCIDENT, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims, or actions that have arisen out of the INCIDENT? If so, for each policy state: (a) the kind of coverage; (b) the name and ADDRESS of the insurance company; (c) the name, ADDRESS, and telephone number of each named insured; (d) the policy number; (e) the limits of coverage for each type of coverage contained in the policy; (f) whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and (g) the name, ADDRESS, and telephone number of the custodian of the policy RESPONSE TO FORM INTERROGATORY NO. 4.1: No (a) N/A
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(b) N/A (c) N/A (d) N/A (e) N/A (f) N/A (g) N/A OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 4.1: Propounding Party has a right to acquire knowledge sufficient to construct his case. FNMA guarantees mortgages by pooling them together to sell to investors. Why did AIG, the huge insurer, go bankrupt insuring FNMA loans? Was Plaintiffs loan involved in a CDS (credit default swap)? FNMA holds a portion of each payment for a mortgage insurance reserve. This is common knowledge. FORM INTERROGATORY NO. 4.2: Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the INCIDENT? If so, specify the statute. RESPONSE TO FORM INTERROGATORY NO. 4.2: No OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 4.2: Propounding Party has a right to acquire knowledge sufficient to construct his case. FNMA guarantees mortgages by pooling them together to sell to investors. Why does the U.S. Treasury pour funds into FNMA to cover losses? Was Plaintiffs loan involved in a CDS (credit default swap)? FNMA holds a portion of each payment for a mortgage insurance reserve. This is common knowledge. If these are the losses Plaintiff has right to information regarding his loan if FNMA held it. FORM INTERROGATORY NO. 12.1: State the name, ADDRESS, and telephone number of each individual: (State the name, ADDRESS, and telephone number of each individual: (a) who witnessed the INCIDENT or the events occurring immediately before or after the INCIDENT; (b) who made any statement at the scene of the INCIDENT; (c) who heard any statements made about the INCIDENT by any individual at the scene; and (d) who YOU OR ANYONE ACTING ON YOUR BEHALF claim has knowledge of the INCIDENT (except for expert witnesses covered by Code of Civil Procedure section 2034). RESPONSE TO FORM INTERROGATORY NO. 12.1: Responding Party objects on the ground this interrogatory seeks information that is not relevant to
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this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 12.1: Propounding Party has a right to acquire knowledge sufficient to construct his case. JP Morgan Chase Bank NA as agent for FNMA, for example, would have been contacted by the Note Holder conveying their decision to declare a default, and their decision to pursue non-judicial foreclosure. As alleged assignee of the Subject Loan Responding Party would have negotiated the terms of the transaction with the prior Note Holder and arranged for the physical transfer of the promissory note if it had not been destroyed. Vague is a sanctionable objection. See Standon v. Superior Court (1990), 225 Cal.App.3d 898 [Court referred to objection of "vague, ambiguous, and unintelligible" "...as a 'nuisance' objection, and not as an attempt to justify a complete failure to comply. Had Kim relied on this objection to the extent of refusing to produce any medical bills or expense documentation, it is beyond question that this would have been subject to sanction."] It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. FORM INTERROGATORY NO. 12.2: Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the INCIDENT? If so, for each individual state: (a) (b) (c) the name, ADDRESS, and telephone number of the individual interviewed; the date of the interview; and the name, ADDRESS, and telephone number of the PERSON who conducted the interview.
RESPONSE TO FORM INTERROGATORY NO. 12.2: Responding Party objects on the ground this interrogatory seeks information that is not relevant to
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this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objection, Responding Party responds as follows: No (a) N/A (b) N/A (c) N/A OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 12.2: Propounding Party has a right to acquire knowledge sufficient to construct his case. JPM as servicer receiving Plaintiffs QWR, for example, would have contacted the Note Holder for a copy of the original promissory note, or might have contacted the possessor of the actual note, or might have contacted someone to forge a copy of the note because the note was no longer available. FORM INTERROGATORY NO. 12.3: Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded statement from any individual concerning the INCIDENT? If so, for each statement state: (a) the name, ADDRESS, and telephone number of the individual from whom the statement was obtained; (b) the name, ADDRESS, and telephone number of the individual who obtained the statement; (c) the date the statement was obtained; and (c) the name, ADDRESS, and telephone number of each PERSON who has the original statement or a copy. RESPONSE TO FORM INTERROGATORY NO. 12.3: Responding Party objects on the ground this interrogatory seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objection, Responding Party responds as
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follows: No (a) (b) (c) (d) N/A N/A N/A N/A
OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 12.3: Propounding Party has a right to acquire knowledge sufficient to construct his case. JPM provided a dump of the collateral file which contained a dialogue of screen shots of computer access to business records. The contact information for the persons capturing those shots are relevant for potential depositions. No dump of a loan or collateral file has been received from FNMA. FORM INTERROGATORY NO. 12.6: Was a report made by any PERSON concerning the INCIDENT? If so, state: (a) the name, title, identification number, and employer of the PERSON who made the report; (b) the date and type of report made; (c) the name, ADDRESS, and telephone number of the PERSON for whom the report was made; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of the report. RESPONSE TO FORM INTERROGATORY NO. 12.6: Responding Party objects on the ground this interrogatory seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objection, Responding Party responds as follows: No (a) (b) (c) (d) N/A N/A N/A N/A
OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 12.6:

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Propounding Party has a right to acquire knowledge sufficient to construct his case. JPM as servicer receiving Plaintiffs QWR, for example, would have contacted the Note Holder for a copy of the original promissory note, or might have contacted the possessor of the actual note, or might have contacted someone to forge a copy of the note because the note was no longer available. Where is the report explaining how the not available promissory note was (re?)produced and turned over to the possession of counsel for JPM? FORM INTERROGATORY NO. 12.7: Have YOU OR ANYONE ACTING ON YOUR BEHALF inspected the scene of the INCIDENT? If so, for each inspection state: (a) the name, ADDRESS, and telephone number of the individual making the inspection (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310); and (b) the date of the inspection. RESPONSE TO FORM INTERROGATORY NO. 12.7: Responding Party objects on the ground this interrogatory seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objection, Responding Party responds as follows: No (a) (b) N/A N/A
OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 12.7: Propounding Party has a right to acquire knowledge sufficient to construct his case. JPM as servicer has added fees for multiple home inspections that were not recorded in the collateral file dump provided by JPM. FORM INTERROGATORY NO. 15.1: Identify each denial of a material allegation and each special or affirmative defense in your
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pleadings and for each: (a) state all facts upon which you base the denial or special or affirmative defense; (b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of tho se facts; and (c) identify all DOCUMENTS and other tangible things that support your denial or special or affirmative defense, and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. RESPONSE TO FORM INTERROGATORY NO. 15.1; Responding Party objects because the interrogatory calls for one or more legal conclusions and/or for information, opinions, or impressions protected by the attorney-client privilege and/or attorney work product doctrine. The interrogatory is vague, ambiguous and uncertain particularly as to the terms "material allegation," "special or affirmative defense," and "PERSONS who have knowledge," and "which support your denial or special or affirmative defense." Responding Party further objects on the grounds that the interrogatory is unduly overbroad, burdensome, and oppressive. Subject to and without waiving these objections, Responding Party states: Second Affirmative Defense - Estoppel Plaintiff is estopped from due to his failure to meet his contractual obligations under the Deed of Trust. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Second, Fourth, Tenth, and Twenty-Third Affirmative Defense in their entirety for failure to produce a pleading that survived demurrer and proclivity for wasting Plaintiffs and the Courts resources. No second amended answer to address these defenses was filed or served per the order of July 20, 2012. Third Affirmative Defense - Waiver Plaintiff has waived any purported right of relief from defendant's foreclosure actions due to Plaintiffs failure to meet his contractual obligations under the Deed of Trust. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909.
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OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff moves to strike as a falsity due to Plaintiffs failure to meet his contractual obligations under the Deed of Trust as Defendant was not named in the Deed of Trust and initiated a suit to prevent Defendant from conducting wrongful foreclosure proceedings. Propounding Party moves to strike Responding Partys Third Affirmative Defense in its entirety for failure to specify a contract obligating Plaintiff that named Defendants. Fourth Affirmative Defense - Unclean Hands Plaintiff is subject to the equitable doctrine of Unclean hands due to his failure to meet his contractual obligations under the Deed of Trust. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Second, Fourth, Tenth, and Twenty-Third Affirmative Defense in their entirety for failure to produce a pleading that survived demurrer and proclivity for wasting Plaintiffs and the Courts resources. No second amended answer to address these defenses was filed or served per the order of July 20, 2012. Fifth Affirmative Defense - Privilege Defendant's foreclosure actions are privileged pursuant to the statutory authority provided in California Civil Code 2923.5 et seq. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Fifth Affirmative Defense in its entirety for failure to specify facts supporting a claim of privilege in a contract to which they are not named and to which the Court has already ruled for Plaintiff. Sixth Affirmative Defense - Ratification Plaintiff ratified Defendant's right to initiate foreclosure proceedings when plaintiff executed the Deed of Trust that specifically provides for the institution of foreclosure proceedings upon
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Defendant's default (See, Deed of Trust, If 19) (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909 OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff moves to strike as a falsity Plaintiff ratified Defendant's right to initiate foreclosure proceedings as Defendant was not named in the Deed of Trust and initiated a suit to prevent Defendant from conducting foreclosure proceedings. Plaintiff moves to strike as a falsity the Deed of Trust that specifically provides for the institution of foreclosure proceedings upon Defendant's default as Defendant was not named in the Deed of Trust and there is no such wording in that document. Propounding Party moves to strike Responding Partys Sixth Affirmative Defense in its entirety for failure to specify facts depicting acts or omissions on the part of Defendants that were ratified by Plaintiff as Defendants are not named parties to the contract. Seventh Affirmative Defense - Consent Plaintiff consented to Defendant's right to initiate foreclosure proceedings when plaintiff executed the Deed of Trust that specifically provides for the institution of foreclosure proceedings upon Defendant's default (See, Deed of Trust, If 19) (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12,1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff moves to strike as a falsity Plaintiff consented to Defendant's right to initiate foreclosure proceedings as Defendant was not named in the Deed of Trust and initiated a suit to prevent Defendant from conducting foreclosure proceedings. Plaintiff moves to strike as a falsity the Deed of Trust that specifically provides for the institution of foreclosure proceedings upon Defendant's default as Defendant was not named in the Deed of Trust and there is no such wording in that document. Propounding Party moves to strike Responding Partys Seventh Affirmative Defense in its entirety for failure to specify the content and extent of any purported promises, representations, concealments,
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and/or omissions, if any there be, that are purportedly attributable to, or made by these answering defendants, and that Plaintiff fully consented thereto.. Eighth Affirmative Defense - Statute of Limitations The Deed of Trust at issue in this matter was executed by the Plaintiff in 1988. More than four years have elapsed since the execution of the deed subjecting this complaint to the four year statute of limitations of Civil Code 337. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Eighth Affirmative Defense in its entirety for failure to specify any statute that applies to the commencement of actions other than for the recovery of real property (Code Civ Proc 335 referring to Code Civ Proc 337). There is no Civil Code 337. Furthermore, the ruling of the Court of July 20, 2012 was Demurrer is also sustained with leave to amend as to the Eighth Affirmative Defense. In stating a statute of limitations defense, Code Civ. Proc. 458 requires that the appropriate Section and Subsection numbers be provided for each cause of action. Ninth Affirmative Defense - No Damages The Plaintiff entered into a loan with the defendant's predecessor and promised to re-pay the sum borrowed, plus interest. The Plaintiff fails and refuses to re-pay the sums owed. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff move to strike as a falsity entered into a loan with the defendant's predecessor as Defendant was not named in the Deed of Trust. Plaintiff moves to strike as a falsity Plaintiff fails and refuses to re-pay the sums owed as Defendant was not named in the Deed of Trust and initiated a wrongful foreclosure proceeding to prevent Plaintiff from acquiring a reverse mortgage to pay off the Subject Loan. Propounding Party moves to strike Responding Partys Ninth Affirmative Defense in its entirety for
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failure to specify facts mitigating Defendants act of misrepresenting their beneficiary interest in Plaintiffs loan, to which they are not a named party, thereby incurring damages to Plaintiff. Tenth Affirmative Defense - Absence of Fault Defendant's right to initiate foreclosure proceedings was made clear in the Deed of Trust that plaintiff executed in 1988 (See, Deed of Trust, If 19) (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Second, Fourth, Tenth, and Twenty-Third Affirmative Defense in their entirety for failure to produce a pleading that survived demurrer and proclivity for wasting Plaintiffs and the Courts resources. No second amended answer to address these defenses was filed or served per the order of July 20, 2012. Eleventh Affirmative Defense - Compliance with Contract and Law Defendant has the right to initiate foreclosure proceedings pursuant to the terms of the Deed of Trust (See, Deed of Trust, f 19), and pursuant to California Civil Code 2923.5 et. seq. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff move to strike as a falsity Defendant has the right to initiate foreclosure proceedings pursuant to the terms of the Deed of Trust as Defendant was not named in the Deed of Trust. Propounding Party moves to strike Responding Partys Eleventh Affirmative Defense in its entirety for failure to specify facts they were in compliance with a contract to which they are not a named party. Thirteenth Affirmative Defense - Reasonableness Defendant initiated foreclosure proceedings pursuant to its rights under the Deed of Trust and pursuant to California civil Code 2923.5. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909.
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OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff move to strike as a falsity pursuant to its rights under the Deed of Trust and as Defendant was not named in the Deed of Trust. Propounding Party moves to strike Responding Partys Thirteenth Affirmative Defense in its entirety for failure to specify facts they acted in a reasonable manner by pursuing a foreclosure when evidence of a loan was not available to them. Fourteenth Affirmative Defense This affirmative defense was raised as a precautionary measure so that the defense would not be waived. Discovery and investigation are continuing. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Fourteenth Affirmative Defense in its entirety for failure to specify facts they were in compliance with a contract to which they are not a named party. As such, they fail to present facts showing how they are exempt from statutorily defined attorney fees. Fifteenth Affirmative Defense - No Punitive Damages Defendant initiated foreclosure proceedings pursuant to its rights under the Deed of Trust and pursuant to California civil Code 2923.5. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff move to strike as a falsity pursuant to its rights under the Deed of Trust as Defendant was not named in the Deed of Trust. Propounding Party moves to strike Responding Partys Fifteenth Affirmative Defense in its entirety for failure to specify facts they were in compliance with California statutes when they caused Plaintiff to stop making payments by failing to return a lawfully requested Qualified Written Request. Seventeenth Affirmative Defense - No Actual Controversy Defendant initiated foreclosure proceedings pursuant to its rights under the Deed of Trust and pursuant to California civil Code 2923.5. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party.
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(c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Seventeenth Affirmative Defense in its entirety for failure to comply with the order of the Court of July 20, 2012 [Plaintiffs Demurrer is sustained without leave to amend with respect to the First, Sixteenth and Seventeenth Affirmative Defenses. The Sixteenth and Seventeenth Affirmative Defenses are not proper defenses because they simply refute elements of the causes of action stated in the complaint.]. Sixteenth Affirmative Defense - Compliance with Foreclosure Laws Defendant initiated foreclosure proceedings pursuant to its rights under the Deed of Trust and pursuant to California civil Code 2923.5. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Sixteenth Affirmative Defense in its entirety for failure to comply with the order of the Court of July 20, 2012 [Plaintiffs Demurrer is sustained without leave to amend with respect to the First, Sixteenth and Seventeenth Affirmative Defenses. The Sixteenth and Seventeenth Affirmative Defenses are not proper defenses because they simply refute elements of the causes of action stated in the complaint.]. Eighteenth Affirmative Defense - Bona Fide Encumbrancer Defendant initiated foreclosure proceedings pursuant to its rights under the Deed of Trust and pursuant to California civil Code 2923.5. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff move to strike as a falsity pursuant to its rights under the Deed of Trust as Defendant was not named in the Deed of Trust. Propounding Party moves to strike Responding Partys Eighteenth Affirmative Defense in its
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entirety for failure to specify facts substantiating beneficiary interest on the part of Defendants that are not named parties to the contract. Furthermore, the Calvo v. HSBC decision rendered the term encumbrancer moot for deed of trust loans as not being other encumbrancers in its interpretation of Civ. Code 2932. Nineteenth Affirmative Defense - Plaintiffs Interest is Subject to Beneficiary's Interest Defendant initiated foreclosure proceedings pursuant to its rights under the Deed of Trust and pursuant to California civil Code 2923.5. (b) Plaintiff and the person deemed most knowledgeable by the Responding Party. (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Plaintiff move to strike as a falsity pursuant to its rights under the Deed of Trust as Defendant was not named in the Deed of Trust. Propounding Party moves to strike Responding Partys Nineteenth Affirmative Defense in its entirety for failure to specify facts substantiating beneficiary or lender or Note Holder interest on the part of Defendants that are not named parties to the contract. Twentieth Affirmative Defense - Right to Add Additional Defenses This affirmative defense was raised as a precautionary measure so that the defense would not be waived. Discovery and investigation are continuing. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 15.1: Propounding Party moves to strike Responding Partys Twentieth, Twenty-First, and TwentySecond Affirmative Defenses in their entirety for failure to specify facts substantiating their claims. Respondents Twientieth Affirmative Defense was renumbered to the Twenty-Third Affirmative Defense in their amended answer. FORM INTERROGATORY NO. 16.1: Do you contend that any PERSON, other than you or plaintiff, contributed to the occurrence of the INCIDENT or the injuries or damages claimed by plaintiff? If so, for each PERSON: (a) state the names ADDRESS, and telephone number of the PERSON; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state
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the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. RESPONSE TO FORM INTERROGATORY NO. 16.1: No (a) (b) (c) (d) N/A N/A N/A N/A
OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 16.1: Propounding Party needs detailed answers to the question asked in light of its affirmative defenses regarding damages from actions of other defendants. FORM INTERROGATORY NO. 16.2: Do you contend that plaintiff was not injured in the INCIDENT? If so: (a) state all facts upon which you base your contention; (b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (c) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. RESPONSE TO FORM INTERROGATORY NO. 16.2: Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Propounding Party's definition of the word "INCIDENT" is the initiation of non-judicial foreclosure proceedings by RESPONDING PARTY pursuant to California Civil Code 2923.5 et seq. By definition, non-judicial foreclosure proceedings pre-suppose the failure of a trustor to fulfill its obligations under a deed of trust. This interrogatory is designed to refer to personal injury. Accordingly, responding Party responds as follows: Yes (a) The plaintiff neglected to honor his obligations under the deed of trust, resulting in the initiation of foreclosure proceedings. (b) Plaintiff (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 16.2: Propounding Party moves to strike as a falsity plaintiff neglected to honor his obligations under the deed of trust, resulting in the initiation of foreclosure proceedings. Plaintiff alleges was induced into
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dishonoring a discredited obligation by illegal acts on the part of Defendants who fail to corroborate their interest in Plaintiffs loan. FORM INTERROGATORY NO. 16.3: Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. RESPONSE TO FORM INTERROGATORY NO. 16.3: Responding Party objects to the term "INCIDENT" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Propounding Party's definition of the word "INCIDENT" is the initiation of non-judicial foreclosure proceedings by RESPONDING PARTY pursuant to California Civil Code 2923.5 et seq. By definition, non-judicial foreclosure proceedings pre-suppose the failure of a trustor to fulfill its obligations under a deed of trust. This interrogatory is designed to refer to personal injury. Accordingly, responding Party responds as follows: Yes (a) The plaintiff neglected to honor his obligations under the deed of trust, resulting in the initiation of foreclosure proceedings. (b) Plaintiff (c) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Notice of Default and Election to Sell Under Deed of Trust dated June 15, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0119320; Notice of Trustee's Sale dated September 22, 2010 and recorded with the Contra Costa County Recorder's Office as Instrument Number 2010-0206909. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 16.3: Propounding Party moves to strike as a falsity plaintiff neglected to honor his obligations under the deed of trust, resulting in the initiation of foreclosure proceedings. Plaintiff was induced into dishonoring a discredited obligation by illegal acts on the part of Defendants who fail to corroborate their interest in Plaintiffs loan. FORM INTERROGATORY NO. 17.1: Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission:
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(a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. RESPONSE TO FORM INTERROGATORY NO. 17.1: (a) 1,2,8,9,10 (b) Defendant is in possession of the original note. As stated in the objection, California law does not require that the original note be in the possession of the party initiating non-judicial foreclosure. See Cal. Civ.Code 2924." San Diego Home Solutions, Inc. v. Reconstrust Co., (S.D.Cal. 2008) 2008 WL 5209972, at *2. See also Putkkuri v. Reconstruct Co., No.08cvl919 WQH (AJB), 2009 WE 32567, at *2 (S.D. Cal. Jan. 5, 2009). (c) Defendant's person most knowledgeable and Plaintiff. (d) Deed of Trust dated May 12, 1988 and recorded with the Contra Costa County Recorder's office as Instrument Number 88-84405; Promissory Note executed by Plaintiff on May 12, 1988. (a) 4,5 (b) Plaintiff claims that his letter of June 9, 2010, is a "Qualified Written Request" under Civil Code 2943. Civil Code 2943, as applied to federally chartered institutions such as JPMorgan, is preempted by Federal law. Lopez v. World Savings & Loan Assn. (2003) 105 Cal.App.4th 729 [130Cal.Rptr.2d42]. (c) N/A (d) Admissions made in Plaintiffs complaint and discovery requests. a) (b) (c) (d) 3,6,7,12 The request is a double negative and/or is unintelligible. Plaintiff N/A
(a) 6 (b) Discovery continues. (c) Discovery continues. (d) Discovery Continues. OBJECTIONS TO RESPONSE TO FORM INTERROGATORY NO. 17.1: Admissions 1, 2, 8, 9, 10 Plaintiff moves to strike the statement Defendant is in possession of the original note from this Response as a false and misleading superfluity. No certified, authenticated document has been presented to substantiate a claim of original note. Admissions 4, 5. Unintelligible is a sanctionable objection. See Standon v. Superior Court (1990), 225 Cal.App.3d 898 [Court referred to objection of "vague, ambiguous, and unintelligible" "...as a 'nuisance' objection, and not as an attempt to justify a complete failure to comply. Had Kim relied on this objection to the extent of refusing to produce any medical bills or expense documentation, it is beyond question that this would have been subject to sanction."] Plaintiff moves to strike this response to the Form Interrogatory as misleading and irrelevant. It is misleading because Plaintiffs letter of June 9 was a reminder letter and referred to the QWR submitted
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to Defendants January 27, 2010. It is irrelevant because Defendant states no facts that defendant FNMA is a chartered national savings bank to which Lopez applies, and Federal regulations upon which the decision was based have since changed. Civil Code 2943 does not affect the servicing1 or status of any element of a loan, it only incidentally affects the lenders operation, and a lenders failure to comply with the statute enables a tort cause of action which is exempted by existing regulation. Admissions 3, 6, and 12 are not double negative. Unintelligible is a sanctionable objection. See Standon v. Superior Court (1990), 225 Cal.App.3d 898 [Motion to compel document production more than 45 days after the response denied as untimely. Court referred to objection of "vague, ambiguous, and unintelligible" "...as a 'nuisance' objection, and not as an attempt to justify a complete failure to comply. Had Kim relied on this objection to the extent of refusing to produce any medical bills or expense documentation, it is beyond question that this would have been subject to sanction."] (a) (b) (c) (d) 6 Discovery continues. Discovery continues. Discovery Continues.
Admission 6 relates to charges against Plaintiffs loan, specifically the fee allowed by California Civ. Code 2943 charged as a result of providing a copy of the promissory note and depicted in the JPM Bates file JPM1 - 523. See Maldonado v. Superior Court (2002), 94 Cal.App.4th 1390 [corporate depsition; "the witness or someone in authority is expected to make an inquiry of everyone who might be holding responsive documents or everyone who knows where such documents might be held."] FORM INTERROGATORY NO. 50.2: Was there a breach of any agreement alleged in the pleadings? If so, for each breach describe and give the date of every act or omission that you claim is the breach of the agreement. RESPONSE TO FORM INTERROGATORY NO. 50.2: Yes, Plaintiff failed and refuses to honor his obligations to make payments under the Deed of Trust and the Promissory Note. OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 50.2: Propounding Party moves to strike Responding Partys phrase and refuses to honor his
The term ``servicing'' means receiving any scheduled periodic payments from a borrower pursuant to the terms of any loan, including amounts for escrow accounts described in section 2609 of this title, and making the payments of principal and interest and such other payments with respect to the amounts received from the borrower as may be required pursuant to the terms of the loan [USC TITLE 12 CHAPTER 27 Sec. 2605(i)(3) Servicing].
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obligations as superfluous, misleading, and without legal basis.
DATED: December 20, 2012 ALVARADOSMITH A Professional Corporation
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: April 13, 2013 __________________________ Leighton Lee Perry, Plaintiff pro se
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1 2 3 4 5 6 7 8 9 10 Leighton Lee PERRY, 11 Plaintiff, 12 vs. 13 14 15 16 17 18 19 20 21 JP MORGAN CHASE BANK N.A.; CHASE HOME FINANCE LLC; FEDERAL NATIONAL MORTGAGE ASSOCIATION; QUALITY LOAN SERVICE CORP.; and all persons unknown, claiming any legal or equitable right, title estate, lien or interest in the property described in this Complaint adverse to Plaintiffs title thereto and as DOES 1-100, Inclusive, Defendants Plaintiff pro se LEIGHTON LEE PERRY
Case # MSC10-02914
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA Case No.: No. MSC10-02914 STATEMENT IN SUPPORT OF MOTION TO COMPEL RESPONSES TO SPECIAL INTERROGATORIES TO FEDERAL NATIONAL MORTGAGE ASSOCIATION (SET TWO)
STATEMENT IN SUPPORT OF MOTION TO COMPEL RESPONSES TO SPECIAL INTERROGATORIES SET TWO Plaintiff Leighton Lee Perry (Propounder), requests that Quality Loan Service Corp (QLS or
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Respondent), answer each of the following special interrogatories, fully and completely under oath,
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within the time and in the manner prescribed by California Code of Civil Procedure 2030.010 et seq.
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As required by California Code of Civil Procedure 2030.010 et seq., each answer must be as
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complete and straightforward as the information available to YOU permits. If an interrogatory cannot be
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answered completely, it must be answered to the extent possible.

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All interrogatories objected to for reason of privilege or trade secret should be listed on a
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EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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privilege log and returned to Plaintiff with the responses. INSTRUCTIONS The term "FNMA" shall mean Defendant Federal National Mortgage Association, their agents, officers, employees, accountants, investigators, and anyone else acting on their behalf. The term "JPMorgan" shall mean Defendant JP Morgan Chase Bank, N.A., their agents, officers, employees, accountants, investigators, and anyone else acting on their behalf. It also references Chase Home Finance, LLC, which was incorporated into JPMorgan subsequent to filing this action., their agents, officers, employees, accountants, investigators, and anyone else acting on their behalf. The term "QLS" shall mean Defendant Quality Loan Service Corp, their agents, officers, employees, accountants, investigators, and anyone else acting on their behalf. The term "YOU" or "YOUR" shall mean Defendant JPMorgan, their agents, officers, employees, accountants, investigators, and anyone else acting on their behalf. The term "DOCUMENT(S) shall mean and include the term "writing" as defined in California Evidence Code 250, and includes writings of any kind in your possession, custody or control, regardless of where located. The term "DOCUMENT(S)" shall further be defined as including all copies of any of the above which bear notations of any sort not present on the original, and all drafts, revisions or amendments of any of the above. The term "DOCUMENT(S)" shall further be defined as including information stored by computer or on a computer disk, diskette, tape or card, as well as any electronic recording, tape recording, video, file, or similar recording of words, sounds, or information of any kind. The term DOCUMENT(S) is synonymous in meaning and equal in scope to the usage of this term in Federal Rule of Civil Procedure 34(a) and includes computer records in any format. A draft or nonidentical copy is a separate document within the meaning of this term. The term DOCUMENT(S) also includes any tangible things as that term is used in Rule 34(a). When referring to a person, identify means to give, to the extent known, the persons full name, present or last known address, telephone number, and when referring to a natural person, the present or last known place of employment. Once a person has been identified in compliance with this paragraph, only the name of that person needs to be listed in response to later discovery requesting the EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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identification of that person. When referring to a document, identify means to give, to the extent known, the following information: (a) the type of document; (b) the general subject matter of the document; (c) the date of the document; (d) the authors, address, and recipients of the document; (e) the location of the document; (f) the identity of the person who has custody of the document; and (g) whether the document has been destroyed, and if so, (i) the date of its destruction, (ii) the reason for its destruction, and (iii) the identity of the person who destroyed it. The term relating means, whether directly or indirectly, concerning; referring; describing; evidencing; or constituting. The term any should be understood in either its most or its least inclusive sense as necessary to bring within the scope of the discovery request all reasons that might otherwise be construed to be outside of its scope The term "Subject Property" shall mean the real property located at 6724 Waverly Rd., Martinez, California 94553 in Contra Costa County, California APN 164-262-026 2. The term "Subject Loan" shall mean the loan made by Valley Federal Savings and Loan to Plaintiff in May of 1988 for $130,000 for purchase of the Subject Property and secured by a deed of trust (DoT) naming All Valley Financial Corporation as Trustee. The term Servicer shall mean any party named or unnamed in this action who receives payments against the Subject Loan and distributes the proceeds. The term "FAA" shall mean the First Amended Answer filed by YOU on or about May 2, 2012, Contra Costa County Superior Court Case No MSC10-02914. The term QWR refers to Plaintiffs Qualified Written Request of January 27, 2010. Each request for interrogatory is to be deemed a continuing one. If, after serving an answer, you obtain or become aware of any further information pertaining to that request, you are requested to serve a supplemental answer setting forth such information. If no such update is provided in a reasonable period of time that you acquired such information, it may be excluded at trial or hearing. Your responses to these Interrogatories may be recorded and presented on standard Compact Disk media in PDF file format. EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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REQUEST FOR INTERROGATORIES SPECIAL INTERROGATORY NO. 1: IDENTIFY each person who answers these interrogatories including attorneys, accountants, employees of third party entities, or any other person consulted, however briefly, on the content of any answer to these special interrogatories. RESPONSE TO SPECIAL INTERROGATORY NO. 1: Responding Party is Federal National Mortgage Association. SPECIAL INTERROGATORY NO. 2: IDENTIFY each person who assisted in answering these interrogatories, including attorneys, accountants, employees of third party entities, or any other person consulted, however briefly, on the content of any answer to these special interrogatories. RESPONSE TO SPECIAL INTERROGATORY NO. 2: David L. Chavez, shareholder, AlvaradoSmith, counsel for Responding Party SPECIAL INTERROGATORY NO. 3: State all facts relating the Subject Loan to "Bowest Corp" depicted on the Assignment of Deed of Trust filed in the Contra Costa County Recorder's Office on or around July 29, 1991 (instrument number 91-150118) of which YOU requested Judicial Notice in YOUR Request for Judicial Notice In Support of Demurrer to Complaint as "Exhibit 2". RESPONSE TO SPECIAL INTERROGATORY NO. 3: Responding Party objects on the ground this interrogatory seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "relating the Subject Loan to" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 3: At the time the Notice of Default was filed the existing status for the original promissory note was not available in paper .. or image format. At the time of the assignment of the Subject Loan to FNMA, Bowest was a mortgage servicing corporation which raises the possibility of who the unnamed beneficiary may actually be. EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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Vague and ambiguous is a sanctionable objection. See Deyo v. Kilbourne (1978), 84 Cal.App.3d 771, 782.[If a party is unable to fully answer it should set forth the efforts made to secure the information.] ["Where the question specific and explicit, an answer which supplies only a portion of the information sought is wholly insufficient. Likewise, a party may not provide deftly worded conclusionary answers designed to evade a series of explicit questions." SPECIAL INTERROGATORY NO. 4: STATE all facts relating to YOUR correspondence dated March 11, 2010 in response to Plaintiffs QWR, signed by Mark Lanceta and titled Requested Documents Not Available. RESPONSE TO SPECIAL INTERROGATORY NO. 4: Responding Party objects to the term "relating to" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Notwithstanding and without waiving the foregoing objection Responding Party responds as follows: The correspondence referenced in Special Interrogatory No. 4 speaks for itself. At the time the letter was sent to the plaintiff the documents were not available. In the intervening time, the documents became available and have been produced to the plaintiff. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 4: Vague and ambiguous is a sanctionable objection. See Deyo v. Kilbourne (1978), 84 Cal.App.3d 771, 782.[If a party is unable to fully answer it should set forth the efforts made to secure the information.] ["Where the question specific and explicit, an answer which supplies only a portion of the information sought is wholly insufficient. Likewise, a party may not provide deftly worded conclusionary answers designed to evade a series of explicit questions." SPECIAL INTERROGATORY NO. 5: State all facts relating to the Subject Loan with respect to YOUR statement in YOUR FAA that"... an Assignment of Deed of Trust was recorded on or about July 29, 1991, with the Contra Costa County Recorder's Offices as instrument number 91-150118, pursuant to which Fannie Mae was assigned all beneficial interest under the Deed of Trust". RESPONSE TO SPECIAL INTERROGATORY NO. 5: Responding Party objects to the entire interrogatory as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. Notwithstanding and EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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without waiving the foregoing objections, Responding Party responds as follows: The Assignment referenced in the Responding Party's answer speaks for itself. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 5: Vague and ambiguous is a sanctionable objection. See Standon v. Superior Court (1990), 225 Cal.App.3d 898 [Motion to compel document production more than 45 days after the response denied as untimely. Court referred to objection of "vague, ambiguous, and unintelligible" "...as a 'nuisance' objection, and not as an attempt to justify a complete failure to comply. Had Kim relied on this objection to the extent of refusing to produce any medical bills or expense documentation, it is beyond question that this would have been subject to sanction."] It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. Noticed documents accepted with objection to the veracity of the contents therein do no speak for themselves [Deyo v. Kilbourne (1978), 84 Cal.App.3d 771, 783."A party may not provide deftly worded conclusionary answers designed to evade a series of explicit questions."] SPECIAL INTERROGATORY NO. 6: State all facts supporting YOUR contention in YOUR FAA [|21] that"... Defendants do possess the original Deed of Trust and Promissory Note" with respect to YOUR statement in the prior sentence that "our record center does not have the requested document available on paper, microfishe, [sic] or image". RESPONSE TO SPECIAL INTERROGATORY NO. 6: Responding Party objects to the entire interrogatory as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objections, Responding Party responds as follows: In its verified answer, the Responding Party admits that a letter was sent to the plaintiff. Responding Party further admitted that such letter stated that the documents requested by the plaintiff were not available at the time the request was made. However, since the date of that letter, the documents have EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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been made available and Responding Party has in fact produced to the plaintiff the original Deed of Trust and Promissory Note. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 6: Vague and ambiguous is a sanctionable objection. See Standon v. Superior Court (1990), 225 Cal.App.3d 898 [Motion to compel document production more than 45 days after the response denied as untimely. Court referred to objection of "vague, ambiguous, and unintelligible" "...as a 'nuisance' objection, and not as an attempt to justify a complete failure to comply. Had Kim relied on this objection to the extent of refusing to produce any medical bills or expense documentation, it is beyond question that this would have been subject to sanction."] It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. See [West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers.] [Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968).] Defendants provide no estimate of effort to substantiate their objection. Plaintiff moves to strike the phrase Promissory Note from the Response a falsity as no forensic or corroborating evidence has been produced to confirm the claim the document in question is not a forgery. SPECIAL INTERROGATORY NO. 7: State all facts relating to a requested copy of the Note by Plaintiff to support YOUR assertion in YOUR FAA [*|27] that "Defendants deny this was the first time this information was provided to Plaintiff. RESPONSE TO SPECIAL INTERROGATORY NO. 7: Responding Party objects to the entire interrogatory as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this interrogatory on the ground that it is burdensome, harassing and oppressive. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 7: Vague and ambiguous is a sanctionable objection. See Standon v. Superior Court (1990), 225 Cal.App.3d 898 [Motion to compel document production more than 45 days after the response denied as untimely. Court referred to objection of "vague, ambiguous, and unintelligible" "...as a 'nuisance' objection, and not as an attempt to justify a complete failure to comply. Had Kim relied on this objection to the extent of refusing to produce any medical bills or expense documentation, it is beyond question that this would have been subject to EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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sanction."] It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. See
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[West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers.] [Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968).] Defendants provide no estimate of effort to substantiate their objection. SPECIAL INTERROGATORY NO. 8: State all facts that support YOUR Third Affirmative Defense that Plaintiff is barred by the equitable doctrine of waiver from any cause of action. RESPONSE TO SPECIAL INTERROGATORY NO. 8: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 8: Unresponsive to instructions on Form Interrogatory. Propounding Party moves to strike Responding Partys Third Affirmative Defense in its entirety for failure to specify a contract obligating Plaintiff. SPECIAL INTERROGATORY NO. 9: State all facts that support YOUR Fifth Affirmative Defense the FAC, including each cause of action contained therein, is barred by virtue of the fact that all of the acts alleged therein to have been performed by Defendants were privileged or justified. RESPONSE TO SPECIAL INTERROGATORY NO. 9: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 9: Unresponsive to instructions on Form Interrogatory. Propounding Party moves to strike Responding Partys Fifth Affirmative Defense in its entirety for failure to specify facts supporting a claim of privilege in a contract to which they are not named. SPECIAL INTERROGATORY NO. 10: State all facts that support YOUR Sixth Affirmative Defense the FAC, including each cause of action therein contained, is barred by Plaintiffs ratification of the actions undertaken. EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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RESPONSE TO SPECIAL INTERROGATORY NO. 10; Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 10: Unresponsive to instructions on Form Interrogatory. Propounding Party moves to strike Responding Partys Sixth Affirmative Defense in its entirety for failure to specify facts depicting acts or omissions on the part of Defendants that were ratified by Plaintiff as Defendants are not named parties to the contract. SPECIALINTERROGATORYNO. 11: State all facts that support YOUR Seventh Affirmative Defense the FAC, including each cause of action contained therein, is barred by Plaintiffs consent. RESPONSE TO SPECIAL INTERROGATORY NO. 11: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 11: Propounding Party moves to strike Responding Partys Seventh Affirmative Defense in its entirety for failure to specify the content and extent of any purported promises, representations, concealments, and/or omissions, if any there be, that are purportedly attributable to, or made by these answering defendants, and that Plaintiff fully consented thereto. SPECIAL INTERROGATORY NO. 12: State all facts that support YOUR Ninth Affirmative Defense the FAC, including each cause of action contained therein, is barred by virtue of the fact that Plaintiff has not suffered, and has not pleaded damages as a result of the conduct alleged in the FAC. RESPONSE TO SPECIAL INTERROGATORY NO. 12: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 12: Propounding Party moves to strike Responding Partys Ninth Affirmative Defense in its entirety for failure to specify facts mitigating Defendants act of misrepresenting their beneficiary interest in Plaintiffs loan, to which they are not a party, thereby incurring damages to Plaintiff. SPECIAL INTERROGATORY NO. 13: EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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State all facts that support YOUR Eleventh Affirmative Defense the FAC, including each cause of action contained therein, is barred because Defendants have fully performed, discharged, and satisfied all obligation and duties imposed upon them by the Subject Loan; any corollary agreements affecting or affected by, the Subject Loan; any agency agreements affecting or affected by, the Subject Loan; and the law. RESPONSE TO SPECIAL INTERROGATORY NO. 13: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 13: Propounding Party moves to strike Responding Partys Eleventh Affirmative Defense in its entirety for failure to specify facts they were in compliance with a contract to which they are not a named party. SPECIAL INTERROGATORY NO. 14: State all facts that support YOUR Twelfth Affirmative Defense the FAC, including each cause of action contained therein, is barred because Plaintiff would be unjustly enriched if he prevailed on his claims. RESPONSE TO SPECIAL INTERROGATORY NO. 14: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 14: This interrogatory is not present in Form Interrogatory No. 15.1. Propounding Party moves to strike Responding Partys Twelfth Affirmative Defense in its entirety for failure to specify facts supporting a claim Plaintiff would be unjustly enriched. SPECIAL INTERROGATORY NO. 15: State all facts that support YOUR Thirteenth Affirmative Defense depicting the reasonable standards applicable to an alleged beneficiary who refuses to be identified. RESPONSE TO SPECIAL INTERROGATORY NO. 15: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 15: Propounding Party moves to strike Responding Partys Thirteenth Affirmative Defense in its entirety for failure to specify facts they acted in a reasonable manner by pursuing a foreclosure when evidence of EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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a loan was not available to them. SPECIAL INTERROGATORY NO. 16: State all facts that support YOUR Fourteenth Affirmative Defense that Plaintiff is not entitled to recover attorney fees. RESPONSE TO SPECIAL INTERROGATORY NO. 16: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 16: Propounding Party moves to strike Responding Partys Fourteenth Affirmative Defense in its entirety for failure to specify facts they were in compliance with a contract to which they are not a named party and to which the court ruled they were not the beneficiary at the time foreclosure proceedings were initiated. As such, they fail to present facts showing how they are exempt from statutorily defined attorney fees. SPECIAL INTERROGATORY NO. 17: State all facts that support YOUR Fifteenth Affirmative Defense that Plaintiff is not entitled to recover punitive or exemplary damages. RESPONSE TO SPECIAL INTERROGATORY NO. 17: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 17: Propounding Party moves to strike Responding Partys Fifteenth Affirmative Defense in its entirety for failure to specify facts they were in compliance with California statutes when they caused Plaintiff to stop making payments by failing to return a lawfully requested Qualified Written Request. SPECIAL INTERROGATORY NO. 18: State all facts that support YOUR Eighteenth Affirmative Defense that the quiet title cause of action does not diminish, modify, and/or affect any right that Respondents have under the subject deed of trust. RESPONSE TO SPECIAL INTERROGATORY NO. 18: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 18: Propounding Party moves to strike Responding Partys Eighteenth Affirmative Defense in its EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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entirety for failure to specify facts substantiating beneficiary interest on the part of Defendants that are not named parties to the contract. SPECIAL INTERROGATORY NO. 19: State all facts that support YOUR Nineteenth Affirmative Defense that this action does not diminish, modify, and/or affect any right that the current beneficiary has in the DOT or in the Subject Property. RESPONSE TO SPECIAL INTERROGATORY NO. 19: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 19: Propounding Party moves to strike Responding Partys Nineteenth Affirmative Defense in its entirety for failure to specify facts substantiating beneficiary or lender or Note Holder interest on the part of Defendants that are not named parties to the contract. SPECIAL INTERROGATORY NO. 20: State all facts that support YOUR Twentieth Affirmative Defense that the current beneficiary of the DOT is a bona fide encumbrancer and holder of the beneficiary interest without claim of defense by Plaintiff. RESPONSE TO SPECIAL INTERROGATORY NO. 20: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 20: Propounding Party moves to strike Responding Partys Twentieth Affirmative Defense in its entirety for failure to specify facts supporting a claim that the current beneficiary of the DOT is a bona fide encumbrancer and holder of the beneficiary interest without claim of defense by Plaintiff. SPECIAL INTERROGATORY NO. 21: State all facts that support YOUR Twenty-first Affirmative Defense that Plaintiff is barred from recovery as against the current beneficiary of the subject DOT based upon the doctrine of equitable subrogation. RESPONSE TO SPECIAL INTERROGATORY NO. 21: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 21: EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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Propounding Party moves to strike Responding Partys Twenty-First Affirmative Defense in its entirety for failure to specify facts substantiating beneficiary or lender or Note Holder interest on the part of Defendants that are not named parties to the contract. SPECIAL INTERROGATORY NO. 22: State all facts that support YOUR Twenty-second Affirmative Defense that establish an entitlement by equitable subrogation of a lien and the right to foreclose upon it if any default thereon arises, that bars Plaintiff from any recovery from YOU. RESPONSE TO SPECIAL INTERROGATORY NO. 22: Objection- This interrogatory is duplicative of Form Interrogatory No. 15. OBJECTION TO RESPONSE TO SPECIAL INTERROGATORY NO. 23: Propounding Party moves to strike Responding Partys Twenty-Second Affirmative Defense in its entirety for failure to specify facts substantiating entitlement by equitable subrogation of a lien and the right to foreclose upon it if any default thereon arises, that bars Plaintiff from any recovery from Defendants. DATED: December 20, 2012
ALVARADOSMITH
A Professional Corporation
Dated: April 13, 2013 __________________________ Leighton Lee Perry, pro se
EXHIBIT B Statements: Requests, Responses, and Objections for Spcl Interrogatories SET TWO
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vs. JP MORGAN CHASE BANK N.A.; CHASE HOME FINANCE LLC; FEDERAL NATIONAL MORTGAGE ASSOCIATION; QUALITY LOAN SERVICE CORP.; and all persons unknown, claiming any legal or equitable right, title estate, lien or interest in the property described in this Complaint adverse to Plaintiffs title thereto and as DOES 1-100, Inclusive, Defendants Leighton Lee PERRY, Plaintiff, Plaintiff pro se LEIGHTON LEE PERRY
Case # MSC10-02914
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA Case No.: No. MSC10-02914 STATEMENT IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS TO FEDERAL NATIONAL MORTGAGE ASSOCIATION (SET TWO)
STATEMENT IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS The following requests for production of documents were served on Respondent JP Morgan Chase Bank NA (including Chase Home Finance, LLC by merger) on November 11, 2012. The responses served on Propounder on December 23, 2012 follow each request. RESPONSES TO PRODUCTION OF DOCUMENTS To the extent that all or any of the requests seek information and / or documents subject to the attorney-client privilege then the Responding Party asserts the attorney-client and / or work product privileges to each of such requests as appropriate and to the extend necessary to avoid a waiver of such privileges. Responding Party responds to each and every discovery request subject to the foregoing, and each of
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the foregoing statements and the objections are incorporated by the reference into each of the following responses: REQUEST FOR PRODUCTION NO. 1: Produce any and all DOCUMENT(S) relating to the transfer of custody and/or physical possession of Plaintiff s original promissory note documenting the Subject Loan. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 1; Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Defendant has produced the original note executed by the plaintiff which is in the possession of the defendant. "Transfer of custody" is irrelevant. Responding Party further objects to this request on the ground that it is burdensome, harassing and oppressive. Responding Party further objects on the grounds that this request is duplicative of requests made and answered previously, in responses to Set One of Plaintiffs Requests for Production of Documents that were served upon the plaintiff on October 20, 2011. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523. ARGUMENT TO REQUEST FOR PRODUCTION NO. 1: Objection Plaintiff moves to strike the phrase Defendant has produced the original note executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Possession of a promissory note by itself is not indicative of a beneficiary interest. Note Holders may retain documents payable to bearer in vaults they do not own. Physical custody is at issue because Defendants cannot explain how they produced an original promissory note presented on paper in 1988, but was unavailable in paper or image format in 2010. Whether a purported document granting beneficiary interest in an action is a forgery under the California Penal Code is highly relevant to this action. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer

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the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). REQUEST FOR PRODUCTION NO. 2: Produce any and all DOCUMENT(S) not recorded with the Contra Costa County Recorder's Office relating to the chain of succession of interest and/or transfer of beneficiary interest in the Subject Loan starting from the original lender, Valley Federal Savings and Loan, to YOU. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Defendant has produced the original note executed by the plaintiff which is in the possession of the defendant. Responding Party further objects to this request on the ground that it is burdensome, harassing and oppressive. Responding Party further objects on the grounds that this request is duplicative of requests made and answered previously, in responses to Set One of Plaintiffs Requests for Production of Documents that were served upon the plaintiff on October 20, 2011. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523. ARGUMENT TO REQUEST FOR PRODUCTION NO. 2: Objection Plaintiff moves to strike the phrase Defendant has produced the original note executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Due to the recent Calvo v HSBC Appellate decision deed of trust loans are not required to be recorded with County Recorders, denying the public interest of knowledge of the likelihood of a clear title and contrary to the TILA regulation that lenders must notify borrowers of change of beneficiary interest and may record those changes with the states recorder offices. Therefore the only existence of an unbroken chain of beneficiary interest is in the business or personal records of the beneficiaries who were / are Note Holders. A potential Note Holder cannot acquire what is not the sellers right to sell. Since the current alleged Note Holder is not named on the original document the business and private

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records of all Note Holders in the chain of interest must be proved. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. Responding Party does not provide what requests were duplicated and what their answers were in particularity. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1253 then their response should be None. REQUEST FOR PRODUCTION NO. 4: Produce any and all DOCUMENT(S) relating the Subject Loan to "POOL # 066627" depicted on the Assignment of Deed of Trust filed in the Contra Costa County Recorder's Office on or around July 29, 1991 (instrument number 91-150118) of which YOU requested Judicial Notice in YOUR Request for Judicial Notice In Support of Demurrer to Complaint as "Exhibit 2". If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Defendant has produced the original note executed by the plaintiff which is in the possession of the defendant. Responding Party further objects to this request on the ground that it is burdensome, harassing and oppressive. Responding Party objects to the term "relating the Subject Loan to POOL #066627"" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. ARGUMENT TO REQUEST FOR PRODUCTION NO. 4: Objection Plaintiff moves to strike the phrase Defendant has produced the original note executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Due to the recent Calvo v HSBC Appellate decision deed of trust loans are not required to be

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recorded with County Recorders, denying the public interest of knowledge of the likelihood of a clear title and contrary to the TILA regulation that lenders must notify borrowers of change of beneficiary interest and may record those changes with the states recorder offices. Therefore the only existence of an unbroken chain of beneficiary interest is in the business or personal records of the beneficiaries who were / are Note Holders. A potential Note Holder cannot acquire what is not the sellers right to sell. Since the current alleged Note Holder is not named on the original document the business and private records of all Note Holders in the chain of interest must be proved. This includes records of the process of converting a loan account into a security asset. The indication of a a second asset or beneficiary identifier on the original loan documents makes this request very relevant. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. REQUEST FOR PRODUCTION NO. 5: Produce any and all DOCUMENT(S) relating YOU to any third party interest in the Subject Loan. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Responding Party objects to the terms "relating YOU" and "third party interest" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. ARGUMENT TO REQUEST FOR PRODUCTION NO. 5: Documents provided by Defendants in JPM 1-523 refer to FNMA as investor, which is not a term on the original contract documents. The term investor connotates the loan account was converted to a security asset, and as such, subject to third party interests, who may have paid off the balance of the Subject Loan from all the billions of dollars the Federal government has poured into FNMAs coffers.

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It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. REQUEST FOR PRODUCTION NO. 6; Produce any and all DOCUMENT(S) relating to any "value or consideration", as defined by California statutes, paid or received for the sale or purchase of the Subject Loan by any and all parties to this action, named or unnamed. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding party objects to the request as unintelligible, vague and ambiguous, causing responding party to speculate as to what documents and information, if any, is responsive. Responding party objects to the terms "all third parties to this action" and "named and unnamed" as vague and ambiguous, causing responding party to speculate as to what documents and information, if any, is responsive. Defendant has produced the original note executed by the plaintiff which is in the possession of the defendant. Responding party objects to this request on the ground that it is burdensome, harassing and oppressive. ARGUMENT TO REQUEST FOR PRODUCTION NO. 6: Objection Plaintiff moves to strike the phrase Defendant has produced the original note executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Due to the recent Calvo v HSBC Appellate decision deed of trust loans are not required to be recorded with County Recorders, denying the public interest of knowledge of the likelihood of a clear title and contrary to the TILA regulation that lenders must notify borrowers of change of beneficiary interest and may record those changes with the states recorder offices. Therefore the only existence of an unbroken chain of beneficiary interest is in the business or personal records of the beneficiaries who

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were / are Note Holders. A potential Note Holder cannot acquire what is not the sellers right to sell. Since the current alleged Note Holder is not named on the original document the business and private records of all Note Holders in the chain of interest must be proved as properly negotiated under the rules of the Universal Commercial Code. This includes records of the sale, receipt, and physical note transfer or possession in general accounting records and / or asset accounting records. Propounder did not use the phrase all third parties to this action in his request but responder should show the attempts made to determine who they may be in his response. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. REQUEST FOR PRODUCTION NO. 7: Produce any and all DOCUMENT(S) relating to any "value or consideration", as defined by California statutes, paid or received by any and all third parties, named or unnamed, as a condition of any transfer of the beneficiary interest of the Subject Loan. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the request as unintelligible, vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to the terms "all third parties to this action" and "named and unnamed" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Defendant has produced the original note executed by the plaintiff which is in the possession of the defendant. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at

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his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 7: Objection Plaintiff moves to strike the phrase Defendant has produced the original note executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Due to the recent Calvo v HSBC Appellate decision deed of trust loans are not required to be recorded with County Recorders, denying the public interest of knowledge of the likelihood of a clear title and contrary to the TILA regulation that lenders must notify borrowers of change of beneficiary interest and may record those changes with the states recorder offices. Therefore the only existence of an unbroken chain of beneficiary interest is in the business or personal records of the beneficiaries who were / are Note Holders. A potential Note Holder cannot acquire what is not the sellers right to sell. Since the current alleged Note Holder is not named on the original document the business and private records of all Note Holders in the chain of interest must be proved as properly negotiated under the rules of the Universal Commercial Code. This includes records of the sale, receipt, and physical note transfer or possession in general accounting records and / or asset accounting records. Responder should show the attempts made to determine who the third parties may be in his response. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-253 then their response should be None. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. REQUEST FOR PRODUCTION NO. 8: Produce any and all DOCUMENT(S) relating to servicing the Subject Loan by any Servicer, named or unnamed. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 8:

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Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the term "relating to servicing" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Responding Party further objects on the grounds that this request is duplicative of requests made and answered previously, in responses to Set One of Plaintiffs Requests for Production of Documents that were served upon the plaintiff on October 20, 2011. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523. ARGUMENT TO REQUEST FOR PRODUCTION NO. 8: California statutes address the change of loan servicer from the perspective of a borrower. They do not address servicers from lenders perspective, or servicers from investor perspective. Plaintiff has the right through discovery to view any agreements defining the roles of all servicers relating to his loan. Given the likelihood the promissory note is a forgery, it is relevant to determine the culpability of anyone dealing with the payments. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. Responding Party does not provide what requests were duplicated and what their answers were in particularity. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1253 then their response should be None. REQUEST FOR PRODUCTION NO. 9: Produce any and all DOCUMENT(S) relating to transfers by assignments and/or succession of interest of the Subject Loan that were not recorded with the Contra Costa County Recorder's Office. If

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none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Defendant has produced the original note and deed of trust executed by the plaintiff which is in the possession of the defendant. ARGUMENT TO REQUEST FOR PRODUCTION NO. 9: Objection Plaintiff moves to strike the phrase Defendant has produced the original note and deed of trust executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Due to the recent Calvo v HSBC Appellate decision deed of trust loans are not required to be recorded with County Recorders, denying the public interest of knowledge of the likelihood of a clear title and contrary to the TILA regulation that lenders must notify borrowers of change of beneficiary interest and may record those changes with the states recorder offices. Therefore the only existence of an unbroken chain of beneficiary interest is in the business or personal records of the beneficiaries who were / are Note Holders. A potential Note Holder cannot acquire what is not the sellers right to sell. Since the current alleged Note Holder is not named on the original document the business and private records of all Note Holders in the chain of interest must be proved. If beneficiary interest is claimed by right of succession, business and / or personal records should document that succession. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. Responding Party does not provide what requests were duplicated and what their answers were in particularity. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1EXHIBIT C Statements: Requests, Responses, and Objections for Produce Documents SET TWO Page 10 of 22

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253 then their response should be None. REQUEST FOR PRODUCTION NO. 10: Produce any and all DOCUMENT(S) relating to any order or request to initiate a non-judicial foreclosure. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Defendant has produced the original note and deed of trust executed by the plaintiff which is in the possession of the defendant. Responding Party further objects on the grounds that this request is duplicative of requests made and answered previously, in responses to Set One of Plaintiffs Requests for Production of Documents that were served upon the plaintiff on October 20, 2011. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523. ARGUMENT TO REQUEST FOR PRODUCTION NO. 9: Objection Plaintiff moves to strike the phrase Defendant has produced the original note and deed of trust executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Plaintiff is simply requesting any documents depicting the beneficiary / principal determined a default had occurred, elected to foreclose, and ordered his agent to to initiate a non-judicial course of action. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that

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respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 11: Produce any and all DOCUMENT(S) relating to any order or request to conduct a non-judicial foreclosure. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Defendant has produced the original note and deed of trust executed by the plaintiff which is in the possession of the defendant. Responding Party further objects on the grounds that this request is duplicative of requests made and answered previously, in responses to Set One of Plaintiffs Requests for Production of Documents that were served upon the plaintiff on October 20, 2011. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523. ARGUMENT TO REQUEST FOR PRODUCTION NO. 11: Objection Plaintiff moves to strike the phrase Defendant has produced the original note and deed of trust executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Plaintiff is simply requesting any documents related to any agent who is conducting a non-judicial course of action. It appears an agent of an agent filed the notice of default, for example. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. Responding Party does not provide what requests were duplicated and what their answers were in particularity. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1EXHIBIT C Statements: Requests, Responses, and Objections for Produce Documents SET TWO Page 12 of 22

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253 then their response should be None. REQUEST FOR PRODUCTION NO. 12; Produce any and all DOCUMENT(S) relating to any insurance related to the Subject Property or the Subject loan. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Defendant has produced the original note and deed of trust executed by the plaintiff which is in the possession of the defendant. ARGUMENT TO REQUEST FOR PRODUCTION NO. 12: Objection Plaintiff moves to strike the phrase Defendant has produced the original note and deed of trust executed by the plaintiff as a superfluous falsity as no certification of the authenticity of the document alleged to be the original promissory note has been entered as evidence. Plaintiff is simply requesting any documents related to any insurance payoffs or claims that would affect the balance of the Subject Loan. Clearly if the loan were paid off there would be no basis for a default and any credit default used at an auction would be a criminal offense. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. REQUEST FOR PRODUCTION NO. 13: Produce any and all DOCUMENT(S) establishing and defining agency relationships among YOU, defendants JPMorgan and QLS, their attorneys in Fact, or any unnamed party that relate to the Subject Loan. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 13:

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Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the terms "establishing and defining" and "agency relationship" as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding Party objects to this request on the ground that it is burdensome, harassing and oppressive. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523. ARGUMENT TO REQUEST FOR PRODUCTION NO. 13: Plaintiff is simply requesting any documents defining any agency relationships among the parties, named or unnamed. It appears an agent of an agent filed the notice of default, for example, so the powers of any agent are relevant. It is not enough that the question or questions are burdensome; the objecting party must also demonstrate that the questions are so unjust that they amount to oppression. West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407, 419, (1961). It must appear that the amount of work required to answer the questions is so great, and the utility of the information sought so minimal, that it would defeat the ends of justice to require answers. Columbia Broadcasting System, Inc. v. Superior Court, 263 CalApp.2d 12, 19 (1968). Defendants provide no estimate of effort to substantiate their objection. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 14: Produce a full and complete copy of the collateral file for Plaintiffs loan. (CD format is acceptable). If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 14; Responding Party objects on the ground this request seeks information that is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Responding Party objects to the terms "collateral fine"[sic] as vague and ambiguous, causing Responding Party to speculate as to what documents and information, if any, is responsive. Responding

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Party objects to this request on the ground that it is burdensome, harassing and oppressive. Responding Party further objects on the grounds that this request is duplicative of requests made and answered previously, in responses to Set One of Plaintiffs Requests for Production of Documents that were served upon the plaintiff on October 20, 2011. Notwithstanding and without waiving the foregoing objection, defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 14: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. Responding Party has use the phrase discovery is ongoing and this is merely an attempt to identify any records added to the corollary file since its presentation to Plaintiff many months ago. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 15: Produce any and all DOCUMENT(S) that support your Third Affirmative Defense that Plaintiff is barred by the equitable doctrine of waiver from any cause of action. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 15: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 16: Produce any and all DOCUMENT(S) that support your Fifth Affirmative Defense the FAC,

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including each cause of action contained therein, is barred by virtue of the fact that all of the acts alleged therein to have been performed by Defendants were privileged or justified. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 16: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 17: Produce any and all DOCUMENT(S) that support your Sixth Affirmative Defense the FAC, including each cause of action contained therein, is barred by Plaintiffs ratification of the actions undertaken. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 17: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 18: Produce any and all DOCUMENT(S) that support your Seventh Affirmative Defense the FAC, including each cause of action contained therein, is barred by Plaintiffs consent. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 18:

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Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 18: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 19: Produce any and all DOCUMENT(S) that support your Ninth Affirmative Defense the FAC, including each cause of action contained therein, is barred by virtue of the fact that Plaintiff has not suffered, and has not pleaded damages as a result of the conduct alleged in the FAC. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 19: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 20: Produce any and all DOCUMENT(S) that support your Eleventh Affirmative Defense the FAC, including each cause of action contained therein, is barred because Defendants have fully performed, discharged, and satisfied all obligation and duties imposed upon them by the Subject Loan; any corollary agreements affecting or affected by, the Subject Loan; any agency agreements affecting or affected by, the Subject Loan; and the law. If none, state "none".

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Case # MSC10-02914
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 20: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 21; Produce any and all DOCUMENT(S) that support your Twelfth Affirmative Defense the FAC, including each cause of action contained therein, is barred because Plaintiff would be unjustly enriched if he prevailed on his claims. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 21: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 21: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 22: Produce any and all DOCUMENT(S) that support your Fourteenth Affirmative Defense that Plaintiff is not entitled to recover attorney'fees. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition.

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Case # MSC10-02914
ARGUMENT TO REQUEST FOR PRODUCTION NO. 22: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 23: Produce any and all DOCUMENT(S) that support your Fifteenth Affirmative Defense that Plaintiff is not entitled to recover punitive or exemplary damages. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 23: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 23: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 24; Produce any and all DOCUMENT(S) that support your Eighteenth Affirmative Defense that the quiet title cause of action does not diminish, modify, and/or affect any right that YOU have under the subject deed of trust. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 24: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any

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Case # MSC10-02914
documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 25; Produce any and all DOCUMENT(S) that support YOUR Nineteenth Affirmative Defense that a current beneficiary exists that holds a beneficiary interest in the Subject Loan. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 25: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 26: Produce any and all DOCUMENT(S) that support your Twentieth Affirmative Defense that the current beneficiary of the DOT was and is a bona fide encumbrancer, for value, and took its beneficial interest in the Subject Loan free and clear of any claims made by Plaintiff. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 26: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None.

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Case # MSC10-02914
REQUEST FOR PRODUCTION NO. 27: Produce any and all DOCUMENT(S) that support your Twenty-first Affirmative Defense that Plaintiff is barred from recovery as against the current beneficiary of the subject DOT based upon the doctrine of equitable subrogation. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 27; Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 27: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None. REQUEST FOR PRODUCTION NO. 28; Produce any and all DOCUMENT(S) that support your Twenty-second Affirmative Defense that establish an entitlement by equitable subrogation of a lien and the right to foreclose upon it if any default thereon arises, that bars Plaintiff from any recovery from YOU. If none, state "none". RESPONSE TO REQUEST FOR PRODUCTION NO. 28: Defendant refers Requesting Party to documents previously produced as JPM 1-523, and to the original documents produced to the plaintiff at his deposition. ARGUMENT TO REQUEST FOR PRODUCTION NO. 28: Objection Plaintiff moves to strike the phrase and to the original documents produced to the plaintiff at his deposition as a superfluous falsity as no certification of the authenticity of any documents alleged to be original have been entered as evidence. If Defendants cannot provide any titles, names, authors, and dates of documents in JPM 1-523 that respond to the request then their response should be None.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true

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Case # MSC10-02914
and correct. Dated: April 13, 2013 __________________________ Leighton Lee Perry, Plaintiff pro se

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT D - Request for Production of Documents SET ONE
Page 1 of 1
Case # MSC10-02914
REQUEST FOR INSPECTION OF DOCUMENTS 1. Produce Plaintiffs original promissory note for inspection by a forensic document expert at a date and time convenient for parties. Plaintiff recommends the Law Offices of AlvaradoSmith in San Framcisco be utilized for copying and inspection. The inspection may involve testing of the paper and ink, and to a very slight degree alter the appearance slightly of the document if a paper sample is taken, but not its content. If not in possession of subject document please state so.
REQUEST FOR PRODUCTION OF DOCUMENTS 1. Produce any and all the transfer and delivery receipts; custodial acceptance receipts; bailee letters; and sales receipts from the transfer of Plaintiffs loan from Valley Federal Savings and Loan 2. Produce any and all Mortgage Loan Schedule, Issue Supplements, Servicing Contract, Supplemental Indenture, and Trust Indenture associated with, and depicting the details of, Plaintiffs loan. 3. Produce any and all "Deposit Agreement(s)" between any party or parties who could claim an interest in Plaintiffs loan including any GSE or other party. If none, state none. 4. Produce any and all "Assignment and Assumption Agreement(s)" between any party or parties who could claim an interest in the loan including any GSE or other party. If none, state none. 5. Produce any and all compliance and exception reports produced by the Custodian responsible for storage of Plaintiffs Promissory Note. If none, state none. 6. Produce any and all the transfer report(s), transmittal report(s), bailee letter(s), and sales receipts from the transfer of Plaintiffs Promissory Note and Deed of Trust from Federal National Mortgage Assn.

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Case # MSC10-02914
REQUEST FOR INTERROGATORIES 1. Please identify each person who answer these interrogatories and each person (attach pages if necessary) who assisted, including attorneys, accountants, employees of third party entities, or any other person consulted, however briefly, on the content of any answer to these interrogatories. ANSWER: 2. For each of the above persons please state whether they have personal knowledge regarding the subject loan transaction. ANSWER: 3. Please state the date of the first contact between April 1, 1988, and December 31, 1991, between FNMA and Valley Federal Savings and Loan in the subject loan transaction; the name, job function, business location, and telephone number of the person(s) in your company who was/were involved in that contact and the name of the contact at Valley Federal Savings and Loan. ANSWER: 4. Please state the dates of subsequent contact(s) between April 1, 1988, and December 31, 1991, between FNMA and Valley Federal Savings and Loan in the subject loan transaction; the name, job function, business location, and telephone number of the person(s) in your company who was/were involved in those contacts and the name of the contact(s) at Valley Federal Savings and Loan. ANSWER: 5. Please state the dates of any agents contact(s) between April 1, 1988, and December 31, 1991, for FNMA or Valley Federal Savings and Loan in the subject loan transaction; the name, job function, business location, and telephone number of the person(s) in your company who was/were involved in those contact(s) and the name, job function, and business location of the agent. ANSWER: 6. Please state the name of the Seller and Master Servicer and the date on which Valley Federal Savings and Loan (originator) sold the subject loan to FNMA, any lending institution, or Sub Servicer of FNMA pool #066627. ANSWER:
PROOF OF SERVICE
Plaintiffs Request for Documents, Admissions, Special and Form Interrogartories from Defendant JPMorgan Chase Bank, N.A. SET TWO (JPM_2)

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Case # MSC10-02914
7. Please identify all persons known or believed by anyone in FNMA or any affiliate to have participated in the securitization of the subject loan including but not limited to mortgage aggregators, mortgage brokers, financial institutions, Structured Investment Vehicles, Special Purpose Vehicles, Trustees, Managers of derivative securities, managers of the company that issued an Asset-backed security, Underwriters, Rating Agency, Credit Enhancement Provider not already identified. ANSWER: 8. Please identify the person(s) or entities that were and are entitled, directly or indirectly to the stream of revenue from the borrower in the subject loan. ANSWER: 9. Please identify the person(s) involved in the underwriting of the subject loan. Underwriting refers to any person who made representations, evaluations or appraisals of value of the security instruments, and likelihood of the borrower to default. ANSWER: 10. Please identify any person(s) who had any contact with any third party regarding the securitization, sale, transfer, assignment, hypothecation or any document or agreement, oral, written or otherwise, that would effect the funding, closing, or the receipt of money from a third party in a transaction that referred to the subject loan that were not presented in items above. ANSWER: 11. Please identify any person(s) known or believed by anyone at FNMA who had received physical possession of Plaintiffs promissory note (and allonges), the mortgage, or any document (including but not limited to assignment, endorsement, allonges, Pooling and Servicing Agreement, Assignment and Assumption Agreement, Trust Agreement, letters or email or faxes of transmittals including attachments) that refers to or incorporates terms regarding the securitization, sale, transfer, assignment, insurance, hypothecation or any document or agreement, oral, written or otherwise, that would effect the funding, or the receipt of money from a third party in a transaction, and whether such money was allocated to principal, interest or other obligation related to the subject loan. ANSWER:
PROOF OF SERVICE

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Case # MSC10-02914
12. Please identify the person(s) in custody of any document that identifies the loan servicer(s) in the subject loan transaction. ANSWER: 13. Please identify any person(s) in custody of any document which refers to any instruction or authority to enforce the note or mortgage in the subject loan transaction. ANSWER: 14. Other than people identified above, identify any and all persons who have or had personal knowledge of the subject loan transaction, underwriting of the subject loan transaction, securitization, sale, transfer, assignment or hypothecation of the subject loan transaction, or the decision to enforce the note or mortgage in the subject loan transaction. ANSWER: 15. Please identify every potential party to this lawsuit not identified above. ANSWER: 16. Please state address, phone number, and employment history for the past 3 years of Tim Bargenquast, Asst. Vice President, McCarthy and Holthus, LLP, Atty in Fact to Federal National Mortgage Association, designated as the Assignor of the mortgage loan to FNMA (Assignment of Deed of Trust recorded in Contra Costa County Registers Office on August 30, 2010). ANSWER: 17. Did Valley Federal Savings and Loan (originator) or previous servicers of this account receive any compensation, fee, commission, payment, rebate or other financial considerations from the Seller and Master Servicer of FNMA or any affiliate or from the trust funds, for handling, processing, originating or administering this loan? ANSWER: 18. Please describe and itemize each and every form of compensation, fee, commission, payment, rebate or other financial consideration paid to Valley Federal Savings and Loan, the originator or previous servicers of this account by FNMA or any affiliate, or from the trust fund. ANSWER:
PROOF OF SERVICE

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Case # MSC10-02914
19. Please identify any party, person or entity known or suspected by FNMA or any of your officers, employees, independent contractors or other agents, or servants of your company who might possess or claim rights under the subject loan or mortgage and/or note. ANSWER: 20. Please identify the custodian of the records that would show all entries regarding the flow of funds for the subject loan transaction prior to and after closing of the loan. (Flow of funds, means any record of money received, any record of money paid out and any bookkeeping or accounting entry, general ledger and accounting treatment of the subject loan transaction at your company or any affiliate including but not limited to whether the subject loan transaction was ever entered into any category on the balance sheet at any time or times, whether any reserve for default was ever entered on the balance sheet, and whether any entry, report or calculation was made regarding the effect of this loan transaction on the capital reserve requirements of your company or any affiliate.) ANSWER: 21. Please identify the auditor and/or accountant of your financial statements or tax returns. ANSWER: 22. Please identify any attorney with whom you consulted or who rendered an opinion regarding the subject loan transaction or any pattern of securitization that may have effected the subject loan transaction directly or indirectly. ANSWER: 23. Please identify any person who served as an officer or director with Federal National Mortgage Association commencing with 6 months prior to closing of the subject loan transaction through December 31, 2010. (This interrogatory is limited only to those people who had knowledge, responsibility, or otherwise made or received reports regarding information that included the subject loan transaction, and/or the process by which solicitation, underwriting and closing of residential mortgage loans, or the securitization, sale, transfer or assignment or hypothecation of residential mortgage loans to third parties.) ANSWER:
PROOF OF SERVICE

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Case # MSC10-02914
24. Did any investor/certificate holder approve or authorize foreclosure proceedings on Plaintiffs property? ANSWER: 25. Please identify the person(s) involved or having knowledge of any insurance policy or product, plan or instrument describing over-collateralization, cross-collateralization or guarantee or other instrument hedging the risk of default as to any person or entity acting as an issuer of any securities or certificates. (Such instrument(s) relate to the composition of a pool, tranche or other aggregation of assets that was created, included or referred to the subject loan and the pool or aggregation was transmitted, transferred, assigned, pledged or hypothecated to any entity or buyer. A person who transmitted, transferred, assigned, pledged or hypothecated refers to any person who suggested, approved, received or accepted the composition of the pool or aggregation made or confirmed representations, evaluations or appraisals of value of the home, value of the security instruments, ability of the borrower to pay.) ANSWER: 26. Please identify the person(s) involved or having knowledge of any credit default swap or other instrument hedging the risk of default as to any person or entity acting as an issuer of any securities or certificates. (Such instrument(s) relate to the composition of a pool, tranche or other aggregation of assets that was created, included or referred to the subject loan.) ANSWER:
Dated August 8, 2011

Motion To Compel Further Discovery Responses From Fannie Mae

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Perry v. JPMorgan Chase Bank N.A.

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

__________________________________ Leighton Lee Perry, Plaintiff pro se

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Plaintiffs Declaration in Support of Motion to Compel Defendant FNMA. SET TWO

Perry v. JPMorgan Chase Bank N.A. et al

Plaintiffs Declaration in Support of Motion to Compel Defendant FNMA. SET TWO

Perry v. JPMorgan Chase Bank N.A. et al

RESPONSE TO FORM INTERROGATORY NO. 2.11; (a) Yes

Perry v. JPMorgan Chase Bank N.A. et al

Federal National Mortgage Association

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

follows: No (a) (b) (c) (d) N/A N/A N/A N/A

OBJECTION TO RESPONSE TO FORM INTERROGATORY NO. 12.6:

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

obligations as superfluous, misleading, and without legal basis.

DATED: December 20, 2012 ALVARADOSMITH A Professional Corporation

Perry v. JPMorgan Chase Bank N.A. et al

answered completely, it must be answered to the extent possible.

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Dated: April 13, 2013 __________________________ Leighton Lee Perry, pro se

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al

Perry v. JPMorgan Chase Bank N.A. et al