promissory note and/or the original deed of trust and for the plaintiffs mortgage loan claimed to be owned

by any of the defendants.

37. All documents setting forth the name, address, and telephone number of the physical custodian of the original promissory note and the original deed of trust for the plaintiffs mortgage loan claimed to be owned by any of the Defendants.

38. All documents setting forth the assignment of either the original promissory note and/or the original deed of trust for the plaintiffs mortgage loan, which are claimed to be owned by any of the defendants, to any particular Specialized Investment Vehicle (SIV), Collateralized Mortgage Obligation (CMO), Collateralized Debt Obligation (CDO), series of mortgage-backed securities or certificates (MBS), or collateral default swap (CDS).

39. All documents setting forth the full name, current address, and telephone number of each holder of or investor in any SIV, CMO, CDO, MBS, or CDS which is collateralized in whole or in part by the plaintiffs mortgage loan or any right incident thereto or thereunder.

40. All documents which identify the full name, current address, and telephone number of all persons who authorized "THE THREAT INCLUDING CUSTOMER INTERACTION DEPARTMENT, CHASE HOME FINANCE, LLC DATED MAY 3, 2010" of any foreclosure "OR COLLECTION ACTIVITY" against the plaintiff the filing of any foreclosure action against the plaintiff.

41. All documents demonstrating the granting of any authority of any kind whatsoever from the original lender to MERS.

42. All documents related to any trust (e.g., trust indenture, trust document, etc.) or trustee (e.g., appointment and powers of trustee for trust) of any trust

AMI CHERI E. HOWER 19888 Seventh St East Sonoma, California, (707) 953-0162 Plaintiff In Pro Se

36. All documents setting forth the present physical location of the original promissory note and/or the original deed of trust and for the plaintiffs mortgage loan claimed to be owned by any of the defendants.

37. All documents setting forth the name, address, and telephone number of the physical custodian of the original promissory note and the original deed of trust for the plaintiffs mortgage loan claimed to be owned by any of the Defendants.

38. All documents setting forth the assignment of either the original promissory note and/or the original deed of trust for the plaintiffs mortgage loan, which are claimed to be owned by any of the defendants, to any particular Specialized Investment Vehicle (SIV), Collateralized Mortgage Obligation (CMO), Collateralized Debt Obligation (CDO), series of mortgage-backed securities or certificates (MBS), or collateral default swap (CDS).

39. All documents setting forth the full name, current address, and telephone number of each holder of or investor in any SIV, CMO, CDO, MBS, or CDS which is collateralized in whole or in part by the plaintiffs mortgage loan or any right incident thereto or thereunder.

40. All documents which identify the full name, current address, and telephone number of all persons who authorized "THE THREAT INCLUDING CUSTOMER INTERACTION DEPARTMENT, CHASE HOME FINANCE, LLC DATED MAY 3, 2010" of any foreclosure "OR COLLECTION ACTIVITY" against the plaintiff the filing of any foreclosure action against the plaintiff.

41. All documents demonstrating the granting of any authority of any kind whatsoever from the original lender to MERS.

COMES NOW Plaintiff AMI CHERIE HOWER plaintiff, appearing In Pro Se, and files her First Request for Production to Defendants which has been served upon Defendants and request that Defendants produce all documents responsive to the attached Schedule A within the time and manner provided by California Rules of Procedure:

Document as utilized herein is to be construed, understood, and intended to mean the original of any and all books, papers, records, logs, ledgers, telefaxes, telexes, microfilm, microfiche, memoranda (whether handwritten, typed, computer-generated, or otherwise), books of account, logbooks, data banks, data bases, and any other manner and/or means of data and/or information storage, including but not limited to computer discs, tape backup or storage, or otherwise. If the original of any requested document is not available, the specific reason(s) for such non-availability shall be specifically stated in your response. Production of the original documents is appropriate under the best evidence rule and California case law.

IF ANY CLAIM OF PRIVILEGE IS MADE AS TO ALL OR ANY PART OF ANY OF THE CATEGORICAL REQUESTS HERE IN BELOW, YOU ARE TO SERVE A PRIVILEGE LOG WITH YOUR RESPONSE TO THIS REQUEST FOR PRODUCTION, WHICH PRIVILEGE LOG SHALL INCLUDE A GENERIC DESCRIPTION OF THE DOCUMENT, THE AUTHOR THEREOF, THE INTENDED RECIPIENT THEREOF, THE DATE THEREOF, AND THE IDENTIFICATION OF ANY PRIVILEGE(S) CLAIMED AS TO THE DOCUMENT.

Documents to be Produced:

1. All Assignments, Allonges, (COPIES OF THE FRONT AND BACK OF THE ORIGINAL PROMISSORY NOTE) which purport to assign any interest in the deed of trust or promissory note of the plaintiff.

2. All documents setting forth any servicing agreement between the Defendants and any entity with reference to the promissory note and deed of trust of the plaintiff.

3. All Pooling and Service Agreements, Custodial Agreements, Deposit Agreements, Master Purchasing Agreements, Issuer Agreements, Commitment to Guarantee Agreements, Release of Document Agreements, Master Agreements for Servicers Principal and Interest Custodial Account, Servicers Escrow Custodial Account Agreements, Release of Interest Agreements, or Trustee Agreements relating to the promissory note or deed of trust of the plaintiff.

4. All documents setting forth the entire Chain of Title to the deed of trust and promissory note of the plaintiff from the original lender to the present owner and holder of the promissory note and deed of trust.

5. The entire loan underwriting file of the plaintiffs mortgage loan, including all documents setting forth the mortgage loan for which the plaintiff qualified and all inquiries made to any lender as to mortgage loans available to the plaintiff. 6. All documents setting forth verification of all payments, fees paid or assessed on the HUD-1 as well as a full accounting of the subject loan from inception to the present.

7. All documents setting forth any authority of the defendants or any agent thereof to institute any foreclosure OR THREAT OF FORECLOSURE or action against the plaintiff.

8. All policies of insurance, including but not limited to private mortgage insurance, insurance in favor of any trustee or loan trust, LPMI policies, NIM

policies, UCC Eagle 9 mezzanine policies, ISDA swap policies, master and bulk supplemental policies, mortgagee title policies, or any other insurance which provides benefits to the Defendants or any party in privity with the defendants or the original lender or successor thereto or securitized trust upon default by the borrower in connection with the plaintiffs mortgage loan.

9. All documents setting forth any claims made against any policy of insurance (AIG OR ANY OTHER INSURANCE COMPANY) the subject of request number 8. above.

10. Any and All documents setting forth any payments made or received in connection with any claim the subject of request number 9. above.

11. All documents setting forth any denial or reservation of rights as to any claim made in connection with any policy of insurance the subject of request number 8. above.

12. All documents demonstrating any funding of the plaintiffs mortgage loan the subject of this request by any certificated or un-certificated security (I.E., "TABLE FUNDING", AS PROVIDED BY THE INVESTORS RESIDENTIAL MBS (MORTGAGE BACKED SECURITIES). 13. All documents concerning any consideration exchanged between any persons or parties in connection with the assignment or sale of any part of, or right under, or right incident to the plaintiffs mortgage loan (e.g. assignment or sale of the deed of trust, assignment or sale of promissory note, assignment or sale of servicing rights, assignment or sale of right to income stream from borrower, payments, assignment to a mortgage pool, assignment to any SIV, CMO, CDO, 14. All credit default swap partner agreements and/or ISDA swap agreements.

15. All documents setting forth all information contained within any mortgage

servicing or accounting computer systems, including but not limited to Alltel or Fidelity CPI systems or any other software, concerning the servicing or subservicing of the plaintiffs mortgage loan from inception of plaintiffs account to the present.

16. All documents identifying any descriptions or legends of all codes utilized within any mortgage servicing or accounting system identified within your response to request number 15. above.

17. All documents evidencing all payments made by the plaintiff or any third party on or toward the loan obligations at any time.

18. All documents setting forth any and all PAYMENTS MADE applied against any and all balances due on the plaintiffs mortgage loan at any time, including amount of credit, date credit applied, source of credit, and obligation to which credit was applied (e.g., principal, interest, late fees, etc.).

19. All documents setting forth the disposition of all payments made by the plaintiff or any third party in connection with the plaintiffs mortgage loan, including but not limited to documentation setting forth amounts assigned to or credited against principal, interest, insurance escrows or payments, tax escrows or payments, late fees, or any other charges.

20. All documents setting forth the treatment of all taxes relating to the plaintiffs mortgage loan, including but not limited to establishment and maintenance of tax escrows, payment of taxes, refund of excess escrows, source of funds for tax escrows and payments.

21. All escrow analysis in reference to the plaintiffs mortgage loan from inception of the account to the present.

22. All documents evidencing any agreement between the originator (ORIGINATOR/BANK), the actual investor, or either of the defendants, or any other person or party and any appraisal company, appraiser, or mortgage broker relating to the plaintiffs mortgage loan or the real property subject to the plaintiffs mortgage loan.

24. All documents evidencing any agreement between the original lender/ investor or any and all third party intermediaries (WALL STREET I.E., LEHMAN BROTHERS, BEAR STERNS, GOLDMAN SACHS, JP MORGAN CHASE ET AL) and any person or party relating to the servicing, in any respect, of the plaintiffs mortgage loan.

25. All documents evidencing any agreement between defendants and any person or party relating to the servicing, in any respect, of the plaintiffs mortgage loan.

26. All documents comprising invoices, bills, or statements for any charges in connection with the Plaintiffs mortgage loans, including but not limited to appraisals, inspections, BPOs (Broker Price Opinions), attorneys fees, accounting fees, and the like whether or not identified on the HUD-1 Settlement Statement.

27. All documents comprising the account servicing records in connection with the plaintiffs mortgage loan relating to calculation of interest, interest rate adjustments, ARM audits, from the inception of the account to the present.

28. All documents relating to any suspense or unapplied account transactions in connection with the plaintiffs mortgage loan from inception of the account to the present.

29. All documents setting forth the assessment of any late fees in connection with the plaintiffs mortgage loan and the treatment thereof (e.g. as liquidated damages, interest, or otherwise).

30. All appraisals and property inspections concerning the plaintiffs real property subject to the mortgage loan claimed to be owned by any of the defendants.

31. All appraisals, evaluations, broker assessments, or other valuations as to the plaintiffs mortgage loans.

32. All documents setting forth any forced-placed insurance on the real property subject to the plaintiffs mortgage loan.

33. All documents setting forth any notice to any of the plaintiffs that any person or party intended to force-place insurance coverage on the plaintiffs real property subject to the mortgage loan claimed to be owned by any of the defendants.

34. All documents signed by the plaintiff authorizing the assessment.

35. All documents evidencing the recording of any assignment of the promissory note or deed of trust as to the plaintiffs mortgage loan claimed to be owned by any of the defendants.

36. All documents setting forth the present physical location of the original promissory note and/or the original deed of trust and for the plaintiffs mortgage loan claimed to be owned by any of the defendants.

37. All documents setting forth the name, address, and telephone number of the physical custodian of the original promissory note and the original deed of

trust for the plaintiffs mortgage loan claimed to be owned by any of the Defendants.

38. All documents setting forth the assignment of either the original promissory note and/or the original deed of trust for the plaintiffs mortgage loan, which are claimed to be owned by any of the defendants, to any particular Specialized Investment Vehicle (SIV), Collateralized Mortgage Obligation (CMO), Collateralized Debt Obligation (CDO), series of mortgage-backed securities or certificates (MBS), or collateral default swap (CDS).

39. All documents setting forth the full name, current address, and telephone number of each holder of or investor in any SIV, CMO, CDO, MBS, or CDS which is collateralized in whole or in part by the plaintiffs mortgage loan or any right incident thereto or thereunder.

40. All documents which identify the full name, current address, and telephone number of all persons who authorized "THE THREAT INCLUDING CUSTOMER INTERACTION DEPARTMENT, CHASE HOME FINANCE, LLC DATED MAY 3, 2010" of any foreclosure "OR COLLECTION ACTIVITY" against the plaintiff the filing of any foreclosure action against the plaintiff.

41. All documents demonstrating the granting of any authority of any kind whatsoever from the original lender to MERS.

42. All documents related to any trust (e.g., trust indenture, trust document, etc.) or trustee (e.g., appointment and powers of trustee for trust) of any trust created incident to the securitization of the plaintiffs mortgage loan.

43. All documents demonstrating the compliance of the REMIC into which the plaintiffs mortgage loan was assigned with Internal Revenue Code section 860.

44. All documents demonstrating compliance by the REMIC or any Trustee with all REMIC qualification guidelines.

45. All documents evidencing the receipt and application of any monies received from or as a result of the Federal Trouble Asset Recovery Program (TARP) including but not limited to any request for such funds based in part on a default of the plaintiffs mortgage loan and application of any such funds toward any such default AS SET FORTH IN THE BLOMBERG REPORT.

46. All documents which provide any authority of MERS or any other person or entity to transfer plaintiffs promissory note and deed of trust into a securitized trust after the closing date thereof.

47. All Governing Documents, memoranda, or other writings setting forth all terms and conditions between any mortgage loan servicer and any alleged owner of the plaintiffs promissory note tied to a mortgage instrument, including notification of claims.

48. The title page to the plaintiffs mortgage loan.

49. IRS Form 1099-OID for the plaintiffs mortgage loan.

50. IRS Form 1066 with accompanying Schedule "Q" for the plaintiffs mortgage loan.

51. All servicing contracts between any and all insurance tracker and any loan servicer as to the plaintiffs mortgage loan and/or any securitized mortgage loan trust into which the plaintiffs mortgage loan was assigned or placed, including all addenda and schedules thereto or identified therein including but

not limited to Service Level Agreements (SLA), Return To Lender (RTL) documents, and any listing of Unable To Locate (UTL) Documents.

52. All documents identifying the Operations Account Manager (OAM) and/or the trustee involved herein for the specific account(s) related to the plaintiffs mortgage loan.

53. All documents concerning or relating to any reports of transactions between financial and foreclosure-related systems as to the plaintiffs mortgage loan, including but not limited to reports provided by Fidelity systems and/or tracked in web-based filing cabinets (including but not limited to Balboa_IT_CCS) and in any system including but not limited to AXSPoint, COOL, or otherwise.

54. Any and All reports of any experts, accountants, and the like upon which any of the defendants intend to rely in any trial of this cause or at any hearing, and any and all documents upon which defendants intend to rely or which defendants intend to introduce into evidence in support of any Motion or at the pending demurer trial of this cause.