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1 IIANDREWE MILLER (BARNO 213504)LORAINE L PEDOWITZ (BAR NO 120614)
211 SARINA SALUJA (BAR NO 253781) ALLEN MATKINS LECK GAMBLE
3 II MALLORY amp NATSIS LLP 515 South Fimeroa Street Ninth Floor
4 II Los AngeleS~Califomia 90071-3309 Phone (213 622-5555
II Fax (213) 20-8816 E-Mai1 amillerallenmatkinscom
6 II lpedowitzcwallenmatkinscomssalujaalrenmatkinscom
7 Attom~ys for Defendant
8 II DEUTSCHE BANK NATIONAL TRUST COMPANY
9 UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA 11
RIVERSIDE DIVISION 12
Chapter 7 In re l3 II I
BRIAN W DAVIES Case No 610-BK-37900-SC 1411 I
Adv No 611-AP-01001-sc II BRIAN W DAVIES an Individual
DEFENDANT DEUTSCHE BANK 16 Plaintiff NATIONAL TRUST COMPANYS
FIRST SET OF INTERROGATORIES 17 v TO PLAINTIFF BRIAN W DAVIES
18 II DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE OF
19 II THE RESIDENTIAL ASSET SECURITIZATION TRUST 2007-A-5
II MORTGAGE PASSTHROUGH CERTIFICATES SERIES 2007-E
21 II UNDER THE POOLING AND SERVICING AGREEMENT DATED
22 II March IS 2007 ITS ASSIGN~ ANDORSUCCE SOR SIN INTERES and all
23 II persons claiming by thr0t or under such person all persons u own
24 II ~laim1Og ani legal ~r equitaJgtle righttItle estate len or 10terest 10 the
II property described in the complaint adverse to Plaintiffs title thereto and
26 II DOES 1-150 Inclusive
2711 Defendants
28
LAW OFFICES Allen Matkins Leck Gamble
Mallory Natals LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 8886640 ILA
INTERROGATORIES TO PLAINTIFF
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1 II PROPOUNDING PARTY Defendant DEUTSCHE BANK NATIONAL
2 II TRUST COMPANY
3 RESPONDING PARTY Plaintiff BRIAN W DAVIES
4 SET NUMBER One
II PLEASE TAKE NOTICE that pursuant to Rule 33 of the Federal Rules of
611 Civil Procedure Rule 7033 ofthe Federal Rules of Bankruptcy Procedure and
7 II Central District Local Rule 7026-3 the Defendant Deutsche Bank National Tnlst
8 II Company as trustee Qfthe Residential Asset Securitization Trust 2007-A-5
9 Mortgage Passthrough Certificates Series 2007-E Under the Pooling and Servicing
Agreement Dated March 1 2007 (Deutsche Bank) hereby requests that Plaintiff
11 Brian W Davies (Plaintiff or Davies) serve his written responses to this First
12 Set of Interrogatories within thirty (30) days after service hereof at Allen Matkins
13 II Leek Gamble Mallory amp Natsis LLP 515 S Figueroa Street 9th Floor Los Angeles
14 California 90071-3398
DEFINITIONS
16 Words printed in BOLDFACE CAPITAL letters are defined herein as
17 follows
18 1 YOU YOUR and DEBTOR mean and include Plaintiff
19 II Brian W Davies the responding party as well as all employees representatives
II attorneys agents successors-in-interest assignors andor any other person or entity
21 II who is acting or is believed to have acted on Brian W Davies behalf
22 2 Deutsche Bank means and includes Defendant Deutsche Bank
23 II National Trust Company as trustee of the Residential Asset Securitization Trust
24 2007-A-5 Mortgage Passthrough Certificates Series 2007-E Under the Pooling and
Servicing Agreement Dated March 12007 the propounding party as well as its
26 II officers directors parents subsidiaries predecessors successors-in-interest
27 II divisions agents employees attorneys accountants investigators and any other
28 II person or entity who is acting or is believed to have acted on its behalf LAWOFFICS -2shyAllen Matkins Leek Gamble
Mallory ampNatals LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA
INTERROGATORIES TO PLAINTIFF
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1 3 RELATING TO and REFERRING TO and RELATING
2 THERETO mean and include alluding to responding to pertaining to connected
3 with commenting on reviewing any aspects of about regarding discussing
4 showing describing mentioning respecting analyzing evidencing constituting
supporting or concerning
6 4 PERSON or PERSONS mean and include in the singular or
7 II plural as appropriate any natural person proprietorship partnership joint venture
8 corporation trust association and all other forms of organization The reference to
9 any PERSON includes all employers employees agents partners officers
directors representatives agents and affiliates of such PERSON if any
11 5 IDENTIFY means to provide a complete description sufficient to
12 II permit the requesting party to locate and identify the subject matter ofany request
13 II When used in relation to any PERSON IDltNTIFY menns to provide the full
14 II name residence address residence telephone number business address business
II telephone number and relationship to YOU of that PERSON When used in
16 II relation to a place IDENTIFY means to provide the complete address of any
17 II place and when used in relation to any object or thing IDENTIFY means to
18 II provide a complete particular description of such object or thing such as by date
19 II type location source and physical description
II 6 COMPLAINT shall refer to YOUR Adversary Complaint filed on
21 II or about January 1 20 1 ~ which is adversary number 6 ll-ap-O 100 I-SC currently
22 II pending in the United States Bankruptcy Court Central District ofCalifornia
23 II Riverside Division
24 II 7 The PROPERTY mean and refers to that certain real property
II located at and commonly known as 43-277 Sentiero Dr Indio CA 92203
26 II 8 The term LOAN shall refer to the Balloon and Planned Unit
27 II Development Note dated November 16 2006 and which was signed by YOU as
28 II well as the Deed of Trust dated November 162006 also signed by YOU and LAW OFFICES -3shy
Allen Matkl ns Leek Gamble Mallory amp Natels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
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1 II which RELATES TO the above-referenced Balloon and Planned Unit
2 II Development Note and secures the Balloon and Planned Unit Development Note
3 against the PROPERTY located at 43-277 Sentiero Dr Indio CA 92203
4 9 COMMUNICATION or COMMUNICATIONS mean and refer
II to any oral written or electronic transmittal of information opinion belief idea or
6 II statement whether made in person by telephone electronic mail voicemail fax
7 mail or by any other means
8 10 DOCUMENT or DOCUMENTS mean and include the original
9 II and every non-identical copy of or attachment to any printed typewritten or
II handwritten matter of whatever character including but not limited to writings as
11 defined by the Federal Rules ofEvidence and any other tangible thing known to
12 YOU in YOUR possession custody or control whether printed recorded
13 reproduced by any process or written or produced by hand and whether or not
14 claimed to be privileged or exempt from production for any reason
11 The term BANKRUPTCY CASE means and includes the Chapter 7
16 II bankruptcy proceeding Case No 610-bk-37900-SC filed on August 312010 and
17 II currently pending in the United States Bankruptcy Court Central District of
18 California Riverside Division
19 12 The term PETITION DATE shall refer to the date on which
DEBTOR filed the bankruptcy petition in the BANKRUPTCY CASE
21 II Please note that the conjunction and shall be interpreted herein inclusively
22 so as not to exclude any information otherwise sought within the scope of these
23 Requests for Production
24
26
27
28 LAW OFFICES
-4shyAllen Matkins Leek Gamble Mallory amp Namls LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGATORIES TO PLAINTIFF
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25
1 INTERROGATORIES
2 INTERROGATORY NO1
3 State all facts RELATING TO the causes of action YOU allege in YOUR
4 COMPLAINT
INTERROGATORY NO2
6 IDENTIFY all PERSONS with knowledge of the facts RELATING TO the
7 causes of action YOU allege in YOUR COMPLAINT
8 INTERROGATORY NO3
9 IDENTIFY all DOCUMENTS RELATING TO the causes of action YOU
allege in YOUR COMPLAINT
11 INTERROGATORY NO4
12 State all facts RELATING TO all damages including but not limited to
13 statutory damages and attorneys fees that YOU claim to have suffered in YOUR
14 COMPLAINT
INTERROGATORY NO5
16 IDENTIFY all PERSONS with knowledge of the facts RELATING TO all
17 damages including but not limited to statutory damages and attorneys fees that
18 YOU claim to have suffered in YOUR COMPLAINT
19 INTERROGATORY NO 6
IDENTIFY all DOCUMENTS RELATING TO all damages including but
21 not limited to statutory damages and attorneys fees that YOU claim to have suffered
22 in YOUR COMPLAINT
23 INTERROGATORY NO 7
24 IDENTIFY all payments YOU have made to any PERSON RELATING
TO all damages including but not limited to attorneys fees that YOU claim to have
26 suffered in YOUR COMPLAINT
27
28
LAW OFFICES -5shyAllen Matkins Leck Gamble Mallory amp Natala LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
8886640 lILA INTERROGATORIES TO PLAINTIFF
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1 INTERROGATORY NO8
2 II IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
3 II COMPLAINT that DEUTSCHE BANK caused to be filed false Assignments of
4 Deed ofTrusts or Wild Deed Instruments with the Riverside County Recorder
INTERROGATORY NO9
6 State all facts RELATING TO YOUR contention in the COMPLAINT
7 that DEUTSCHE BANK caused to be filed false Assignments ofDeed ofTrusts
8 or Wild Deed Instruments with the Riverside County Recorder
9 INTERROGATORY NO 10
IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
11 COMPLAINT that DEUTSCHE BANK as Trustee holds only nominal Legal
12 Title to represent the trust
13 INTERROGATORY NO 11
14 State all facts RELATING TO YOUR contention in the COMPLAINT
that that DEUTSCHE BANK as Trustee holds only nominal Legal Title to
16 1 represent the trust
17 INTERROGATORYNO12
18 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
19 COMPLAINT that the Deed ofTrust has no value since it is wholly insecured
INTERROGATORY NO 13
21 State all facts RELATING TO YOUR contention in the COMPLAINT
22 that that the Deed ofTrust has no value since it is wholly insecured
23 INTERROGATORY NO 14
24 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that if [Deutsche Bank National Trust Company] purchased the
26 Promissory Note and paid MERS such assignment would constitute fraudulent
27 conveyance
28
LAW OFFICES -6shyAllen Matkins leek Gamble Mallory amp Nats llP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
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1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
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10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
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ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
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10
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20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
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7
8 II
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17
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28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
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1 II PROPOUNDING PARTY Defendant DEUTSCHE BANK NATIONAL
2 II TRUST COMPANY
3 RESPONDING PARTY Plaintiff BRIAN W DAVIES
4 SET NUMBER One
II PLEASE TAKE NOTICE that pursuant to Rule 33 of the Federal Rules of
611 Civil Procedure Rule 7033 ofthe Federal Rules of Bankruptcy Procedure and
7 II Central District Local Rule 7026-3 the Defendant Deutsche Bank National Tnlst
8 II Company as trustee Qfthe Residential Asset Securitization Trust 2007-A-5
9 Mortgage Passthrough Certificates Series 2007-E Under the Pooling and Servicing
Agreement Dated March 1 2007 (Deutsche Bank) hereby requests that Plaintiff
11 Brian W Davies (Plaintiff or Davies) serve his written responses to this First
12 Set of Interrogatories within thirty (30) days after service hereof at Allen Matkins
13 II Leek Gamble Mallory amp Natsis LLP 515 S Figueroa Street 9th Floor Los Angeles
14 California 90071-3398
DEFINITIONS
16 Words printed in BOLDFACE CAPITAL letters are defined herein as
17 follows
18 1 YOU YOUR and DEBTOR mean and include Plaintiff
19 II Brian W Davies the responding party as well as all employees representatives
II attorneys agents successors-in-interest assignors andor any other person or entity
21 II who is acting or is believed to have acted on Brian W Davies behalf
22 2 Deutsche Bank means and includes Defendant Deutsche Bank
23 II National Trust Company as trustee of the Residential Asset Securitization Trust
24 2007-A-5 Mortgage Passthrough Certificates Series 2007-E Under the Pooling and
Servicing Agreement Dated March 12007 the propounding party as well as its
26 II officers directors parents subsidiaries predecessors successors-in-interest
27 II divisions agents employees attorneys accountants investigators and any other
28 II person or entity who is acting or is believed to have acted on its behalf LAWOFFICS -2shyAllen Matkins Leek Gamble
Mallory ampNatals LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA
INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 3 RELATING TO and REFERRING TO and RELATING
2 THERETO mean and include alluding to responding to pertaining to connected
3 with commenting on reviewing any aspects of about regarding discussing
4 showing describing mentioning respecting analyzing evidencing constituting
supporting or concerning
6 4 PERSON or PERSONS mean and include in the singular or
7 II plural as appropriate any natural person proprietorship partnership joint venture
8 corporation trust association and all other forms of organization The reference to
9 any PERSON includes all employers employees agents partners officers
directors representatives agents and affiliates of such PERSON if any
11 5 IDENTIFY means to provide a complete description sufficient to
12 II permit the requesting party to locate and identify the subject matter ofany request
13 II When used in relation to any PERSON IDltNTIFY menns to provide the full
14 II name residence address residence telephone number business address business
II telephone number and relationship to YOU of that PERSON When used in
16 II relation to a place IDENTIFY means to provide the complete address of any
17 II place and when used in relation to any object or thing IDENTIFY means to
18 II provide a complete particular description of such object or thing such as by date
19 II type location source and physical description
II 6 COMPLAINT shall refer to YOUR Adversary Complaint filed on
21 II or about January 1 20 1 ~ which is adversary number 6 ll-ap-O 100 I-SC currently
22 II pending in the United States Bankruptcy Court Central District ofCalifornia
23 II Riverside Division
24 II 7 The PROPERTY mean and refers to that certain real property
II located at and commonly known as 43-277 Sentiero Dr Indio CA 92203
26 II 8 The term LOAN shall refer to the Balloon and Planned Unit
27 II Development Note dated November 16 2006 and which was signed by YOU as
28 II well as the Deed of Trust dated November 162006 also signed by YOU and LAW OFFICES -3shy
Allen Matkl ns Leek Gamble Mallory amp Natels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II which RELATES TO the above-referenced Balloon and Planned Unit
2 II Development Note and secures the Balloon and Planned Unit Development Note
3 against the PROPERTY located at 43-277 Sentiero Dr Indio CA 92203
4 9 COMMUNICATION or COMMUNICATIONS mean and refer
II to any oral written or electronic transmittal of information opinion belief idea or
6 II statement whether made in person by telephone electronic mail voicemail fax
7 mail or by any other means
8 10 DOCUMENT or DOCUMENTS mean and include the original
9 II and every non-identical copy of or attachment to any printed typewritten or
II handwritten matter of whatever character including but not limited to writings as
11 defined by the Federal Rules ofEvidence and any other tangible thing known to
12 YOU in YOUR possession custody or control whether printed recorded
13 reproduced by any process or written or produced by hand and whether or not
14 claimed to be privileged or exempt from production for any reason
11 The term BANKRUPTCY CASE means and includes the Chapter 7
16 II bankruptcy proceeding Case No 610-bk-37900-SC filed on August 312010 and
17 II currently pending in the United States Bankruptcy Court Central District of
18 California Riverside Division
19 12 The term PETITION DATE shall refer to the date on which
DEBTOR filed the bankruptcy petition in the BANKRUPTCY CASE
21 II Please note that the conjunction and shall be interpreted herein inclusively
22 so as not to exclude any information otherwise sought within the scope of these
23 Requests for Production
24
26
27
28 LAW OFFICES
-4shyAllen Matkins Leek Gamble Mallory amp Namls LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORIES
2 INTERROGATORY NO1
3 State all facts RELATING TO the causes of action YOU allege in YOUR
4 COMPLAINT
INTERROGATORY NO2
6 IDENTIFY all PERSONS with knowledge of the facts RELATING TO the
7 causes of action YOU allege in YOUR COMPLAINT
8 INTERROGATORY NO3
9 IDENTIFY all DOCUMENTS RELATING TO the causes of action YOU
allege in YOUR COMPLAINT
11 INTERROGATORY NO4
12 State all facts RELATING TO all damages including but not limited to
13 statutory damages and attorneys fees that YOU claim to have suffered in YOUR
14 COMPLAINT
INTERROGATORY NO5
16 IDENTIFY all PERSONS with knowledge of the facts RELATING TO all
17 damages including but not limited to statutory damages and attorneys fees that
18 YOU claim to have suffered in YOUR COMPLAINT
19 INTERROGATORY NO 6
IDENTIFY all DOCUMENTS RELATING TO all damages including but
21 not limited to statutory damages and attorneys fees that YOU claim to have suffered
22 in YOUR COMPLAINT
23 INTERROGATORY NO 7
24 IDENTIFY all payments YOU have made to any PERSON RELATING
TO all damages including but not limited to attorneys fees that YOU claim to have
26 suffered in YOUR COMPLAINT
27
28
LAW OFFICES -5shyAllen Matkins Leck Gamble Mallory amp Natala LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
8886640 lILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORY NO8
2 II IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
3 II COMPLAINT that DEUTSCHE BANK caused to be filed false Assignments of
4 Deed ofTrusts or Wild Deed Instruments with the Riverside County Recorder
INTERROGATORY NO9
6 State all facts RELATING TO YOUR contention in the COMPLAINT
7 that DEUTSCHE BANK caused to be filed false Assignments ofDeed ofTrusts
8 or Wild Deed Instruments with the Riverside County Recorder
9 INTERROGATORY NO 10
IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
11 COMPLAINT that DEUTSCHE BANK as Trustee holds only nominal Legal
12 Title to represent the trust
13 INTERROGATORY NO 11
14 State all facts RELATING TO YOUR contention in the COMPLAINT
that that DEUTSCHE BANK as Trustee holds only nominal Legal Title to
16 1 represent the trust
17 INTERROGATORYNO12
18 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
19 COMPLAINT that the Deed ofTrust has no value since it is wholly insecured
INTERROGATORY NO 13
21 State all facts RELATING TO YOUR contention in the COMPLAINT
22 that that the Deed ofTrust has no value since it is wholly insecured
23 INTERROGATORY NO 14
24 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that if [Deutsche Bank National Trust Company] purchased the
26 Promissory Note and paid MERS such assignment would constitute fraudulent
27 conveyance
28
LAW OFFICES -6shyAllen Matkins leek Gamble Mallory amp Nats llP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
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ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
1 3 RELATING TO and REFERRING TO and RELATING
2 THERETO mean and include alluding to responding to pertaining to connected
3 with commenting on reviewing any aspects of about regarding discussing
4 showing describing mentioning respecting analyzing evidencing constituting
supporting or concerning
6 4 PERSON or PERSONS mean and include in the singular or
7 II plural as appropriate any natural person proprietorship partnership joint venture
8 corporation trust association and all other forms of organization The reference to
9 any PERSON includes all employers employees agents partners officers
directors representatives agents and affiliates of such PERSON if any
11 5 IDENTIFY means to provide a complete description sufficient to
12 II permit the requesting party to locate and identify the subject matter ofany request
13 II When used in relation to any PERSON IDltNTIFY menns to provide the full
14 II name residence address residence telephone number business address business
II telephone number and relationship to YOU of that PERSON When used in
16 II relation to a place IDENTIFY means to provide the complete address of any
17 II place and when used in relation to any object or thing IDENTIFY means to
18 II provide a complete particular description of such object or thing such as by date
19 II type location source and physical description
II 6 COMPLAINT shall refer to YOUR Adversary Complaint filed on
21 II or about January 1 20 1 ~ which is adversary number 6 ll-ap-O 100 I-SC currently
22 II pending in the United States Bankruptcy Court Central District ofCalifornia
23 II Riverside Division
24 II 7 The PROPERTY mean and refers to that certain real property
II located at and commonly known as 43-277 Sentiero Dr Indio CA 92203
26 II 8 The term LOAN shall refer to the Balloon and Planned Unit
27 II Development Note dated November 16 2006 and which was signed by YOU as
28 II well as the Deed of Trust dated November 162006 also signed by YOU and LAW OFFICES -3shy
Allen Matkl ns Leek Gamble Mallory amp Natels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II which RELATES TO the above-referenced Balloon and Planned Unit
2 II Development Note and secures the Balloon and Planned Unit Development Note
3 against the PROPERTY located at 43-277 Sentiero Dr Indio CA 92203
4 9 COMMUNICATION or COMMUNICATIONS mean and refer
II to any oral written or electronic transmittal of information opinion belief idea or
6 II statement whether made in person by telephone electronic mail voicemail fax
7 mail or by any other means
8 10 DOCUMENT or DOCUMENTS mean and include the original
9 II and every non-identical copy of or attachment to any printed typewritten or
II handwritten matter of whatever character including but not limited to writings as
11 defined by the Federal Rules ofEvidence and any other tangible thing known to
12 YOU in YOUR possession custody or control whether printed recorded
13 reproduced by any process or written or produced by hand and whether or not
14 claimed to be privileged or exempt from production for any reason
11 The term BANKRUPTCY CASE means and includes the Chapter 7
16 II bankruptcy proceeding Case No 610-bk-37900-SC filed on August 312010 and
17 II currently pending in the United States Bankruptcy Court Central District of
18 California Riverside Division
19 12 The term PETITION DATE shall refer to the date on which
DEBTOR filed the bankruptcy petition in the BANKRUPTCY CASE
21 II Please note that the conjunction and shall be interpreted herein inclusively
22 so as not to exclude any information otherwise sought within the scope of these
23 Requests for Production
24
26
27
28 LAW OFFICES
-4shyAllen Matkins Leek Gamble Mallory amp Namls LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORIES
2 INTERROGATORY NO1
3 State all facts RELATING TO the causes of action YOU allege in YOUR
4 COMPLAINT
INTERROGATORY NO2
6 IDENTIFY all PERSONS with knowledge of the facts RELATING TO the
7 causes of action YOU allege in YOUR COMPLAINT
8 INTERROGATORY NO3
9 IDENTIFY all DOCUMENTS RELATING TO the causes of action YOU
allege in YOUR COMPLAINT
11 INTERROGATORY NO4
12 State all facts RELATING TO all damages including but not limited to
13 statutory damages and attorneys fees that YOU claim to have suffered in YOUR
14 COMPLAINT
INTERROGATORY NO5
16 IDENTIFY all PERSONS with knowledge of the facts RELATING TO all
17 damages including but not limited to statutory damages and attorneys fees that
18 YOU claim to have suffered in YOUR COMPLAINT
19 INTERROGATORY NO 6
IDENTIFY all DOCUMENTS RELATING TO all damages including but
21 not limited to statutory damages and attorneys fees that YOU claim to have suffered
22 in YOUR COMPLAINT
23 INTERROGATORY NO 7
24 IDENTIFY all payments YOU have made to any PERSON RELATING
TO all damages including but not limited to attorneys fees that YOU claim to have
26 suffered in YOUR COMPLAINT
27
28
LAW OFFICES -5shyAllen Matkins Leck Gamble Mallory amp Natala LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
8886640 lILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORY NO8
2 II IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
3 II COMPLAINT that DEUTSCHE BANK caused to be filed false Assignments of
4 Deed ofTrusts or Wild Deed Instruments with the Riverside County Recorder
INTERROGATORY NO9
6 State all facts RELATING TO YOUR contention in the COMPLAINT
7 that DEUTSCHE BANK caused to be filed false Assignments ofDeed ofTrusts
8 or Wild Deed Instruments with the Riverside County Recorder
9 INTERROGATORY NO 10
IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
11 COMPLAINT that DEUTSCHE BANK as Trustee holds only nominal Legal
12 Title to represent the trust
13 INTERROGATORY NO 11
14 State all facts RELATING TO YOUR contention in the COMPLAINT
that that DEUTSCHE BANK as Trustee holds only nominal Legal Title to
16 1 represent the trust
17 INTERROGATORYNO12
18 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
19 COMPLAINT that the Deed ofTrust has no value since it is wholly insecured
INTERROGATORY NO 13
21 State all facts RELATING TO YOUR contention in the COMPLAINT
22 that that the Deed ofTrust has no value since it is wholly insecured
23 INTERROGATORY NO 14
24 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that if [Deutsche Bank National Trust Company] purchased the
26 Promissory Note and paid MERS such assignment would constitute fraudulent
27 conveyance
28
LAW OFFICES -6shyAllen Matkins leek Gamble Mallory amp Nats llP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
17
18
19
21
22
23
24
26
27
28
ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
1 II which RELATES TO the above-referenced Balloon and Planned Unit
2 II Development Note and secures the Balloon and Planned Unit Development Note
3 against the PROPERTY located at 43-277 Sentiero Dr Indio CA 92203
4 9 COMMUNICATION or COMMUNICATIONS mean and refer
II to any oral written or electronic transmittal of information opinion belief idea or
6 II statement whether made in person by telephone electronic mail voicemail fax
7 mail or by any other means
8 10 DOCUMENT or DOCUMENTS mean and include the original
9 II and every non-identical copy of or attachment to any printed typewritten or
II handwritten matter of whatever character including but not limited to writings as
11 defined by the Federal Rules ofEvidence and any other tangible thing known to
12 YOU in YOUR possession custody or control whether printed recorded
13 reproduced by any process or written or produced by hand and whether or not
14 claimed to be privileged or exempt from production for any reason
11 The term BANKRUPTCY CASE means and includes the Chapter 7
16 II bankruptcy proceeding Case No 610-bk-37900-SC filed on August 312010 and
17 II currently pending in the United States Bankruptcy Court Central District of
18 California Riverside Division
19 12 The term PETITION DATE shall refer to the date on which
DEBTOR filed the bankruptcy petition in the BANKRUPTCY CASE
21 II Please note that the conjunction and shall be interpreted herein inclusively
22 so as not to exclude any information otherwise sought within the scope of these
23 Requests for Production
24
26
27
28 LAW OFFICES
-4shyAllen Matkins Leek Gamble Mallory amp Namls LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORIES
2 INTERROGATORY NO1
3 State all facts RELATING TO the causes of action YOU allege in YOUR
4 COMPLAINT
INTERROGATORY NO2
6 IDENTIFY all PERSONS with knowledge of the facts RELATING TO the
7 causes of action YOU allege in YOUR COMPLAINT
8 INTERROGATORY NO3
9 IDENTIFY all DOCUMENTS RELATING TO the causes of action YOU
allege in YOUR COMPLAINT
11 INTERROGATORY NO4
12 State all facts RELATING TO all damages including but not limited to
13 statutory damages and attorneys fees that YOU claim to have suffered in YOUR
14 COMPLAINT
INTERROGATORY NO5
16 IDENTIFY all PERSONS with knowledge of the facts RELATING TO all
17 damages including but not limited to statutory damages and attorneys fees that
18 YOU claim to have suffered in YOUR COMPLAINT
19 INTERROGATORY NO 6
IDENTIFY all DOCUMENTS RELATING TO all damages including but
21 not limited to statutory damages and attorneys fees that YOU claim to have suffered
22 in YOUR COMPLAINT
23 INTERROGATORY NO 7
24 IDENTIFY all payments YOU have made to any PERSON RELATING
TO all damages including but not limited to attorneys fees that YOU claim to have
26 suffered in YOUR COMPLAINT
27
28
LAW OFFICES -5shyAllen Matkins Leck Gamble Mallory amp Natala LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
8886640 lILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORY NO8
2 II IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
3 II COMPLAINT that DEUTSCHE BANK caused to be filed false Assignments of
4 Deed ofTrusts or Wild Deed Instruments with the Riverside County Recorder
INTERROGATORY NO9
6 State all facts RELATING TO YOUR contention in the COMPLAINT
7 that DEUTSCHE BANK caused to be filed false Assignments ofDeed ofTrusts
8 or Wild Deed Instruments with the Riverside County Recorder
9 INTERROGATORY NO 10
IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
11 COMPLAINT that DEUTSCHE BANK as Trustee holds only nominal Legal
12 Title to represent the trust
13 INTERROGATORY NO 11
14 State all facts RELATING TO YOUR contention in the COMPLAINT
that that DEUTSCHE BANK as Trustee holds only nominal Legal Title to
16 1 represent the trust
17 INTERROGATORYNO12
18 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
19 COMPLAINT that the Deed ofTrust has no value since it is wholly insecured
INTERROGATORY NO 13
21 State all facts RELATING TO YOUR contention in the COMPLAINT
22 that that the Deed ofTrust has no value since it is wholly insecured
23 INTERROGATORY NO 14
24 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that if [Deutsche Bank National Trust Company] purchased the
26 Promissory Note and paid MERS such assignment would constitute fraudulent
27 conveyance
28
LAW OFFICES -6shyAllen Matkins leek Gamble Mallory amp Nats llP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
17
18
19
21
22
23
24
26
27
28
ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORIES
2 INTERROGATORY NO1
3 State all facts RELATING TO the causes of action YOU allege in YOUR
4 COMPLAINT
INTERROGATORY NO2
6 IDENTIFY all PERSONS with knowledge of the facts RELATING TO the
7 causes of action YOU allege in YOUR COMPLAINT
8 INTERROGATORY NO3
9 IDENTIFY all DOCUMENTS RELATING TO the causes of action YOU
allege in YOUR COMPLAINT
11 INTERROGATORY NO4
12 State all facts RELATING TO all damages including but not limited to
13 statutory damages and attorneys fees that YOU claim to have suffered in YOUR
14 COMPLAINT
INTERROGATORY NO5
16 IDENTIFY all PERSONS with knowledge of the facts RELATING TO all
17 damages including but not limited to statutory damages and attorneys fees that
18 YOU claim to have suffered in YOUR COMPLAINT
19 INTERROGATORY NO 6
IDENTIFY all DOCUMENTS RELATING TO all damages including but
21 not limited to statutory damages and attorneys fees that YOU claim to have suffered
22 in YOUR COMPLAINT
23 INTERROGATORY NO 7
24 IDENTIFY all payments YOU have made to any PERSON RELATING
TO all damages including but not limited to attorneys fees that YOU claim to have
26 suffered in YOUR COMPLAINT
27
28
LAW OFFICES -5shyAllen Matkins Leck Gamble Mallory amp Natala LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
8886640 lILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORY NO8
2 II IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
3 II COMPLAINT that DEUTSCHE BANK caused to be filed false Assignments of
4 Deed ofTrusts or Wild Deed Instruments with the Riverside County Recorder
INTERROGATORY NO9
6 State all facts RELATING TO YOUR contention in the COMPLAINT
7 that DEUTSCHE BANK caused to be filed false Assignments ofDeed ofTrusts
8 or Wild Deed Instruments with the Riverside County Recorder
9 INTERROGATORY NO 10
IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
11 COMPLAINT that DEUTSCHE BANK as Trustee holds only nominal Legal
12 Title to represent the trust
13 INTERROGATORY NO 11
14 State all facts RELATING TO YOUR contention in the COMPLAINT
that that DEUTSCHE BANK as Trustee holds only nominal Legal Title to
16 1 represent the trust
17 INTERROGATORYNO12
18 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
19 COMPLAINT that the Deed ofTrust has no value since it is wholly insecured
INTERROGATORY NO 13
21 State all facts RELATING TO YOUR contention in the COMPLAINT
22 that that the Deed ofTrust has no value since it is wholly insecured
23 INTERROGATORY NO 14
24 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that if [Deutsche Bank National Trust Company] purchased the
26 Promissory Note and paid MERS such assignment would constitute fraudulent
27 conveyance
28
LAW OFFICES -6shyAllen Matkins leek Gamble Mallory amp Nats llP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
17
18
19
21
22
23
24
26
27
28
ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
1 INTERROGATORY NO8
2 II IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
3 II COMPLAINT that DEUTSCHE BANK caused to be filed false Assignments of
4 Deed ofTrusts or Wild Deed Instruments with the Riverside County Recorder
INTERROGATORY NO9
6 State all facts RELATING TO YOUR contention in the COMPLAINT
7 that DEUTSCHE BANK caused to be filed false Assignments ofDeed ofTrusts
8 or Wild Deed Instruments with the Riverside County Recorder
9 INTERROGATORY NO 10
IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
11 COMPLAINT that DEUTSCHE BANK as Trustee holds only nominal Legal
12 Title to represent the trust
13 INTERROGATORY NO 11
14 State all facts RELATING TO YOUR contention in the COMPLAINT
that that DEUTSCHE BANK as Trustee holds only nominal Legal Title to
16 1 represent the trust
17 INTERROGATORYNO12
18 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
19 COMPLAINT that the Deed ofTrust has no value since it is wholly insecured
INTERROGATORY NO 13
21 State all facts RELATING TO YOUR contention in the COMPLAINT
22 that that the Deed ofTrust has no value since it is wholly insecured
23 INTERROGATORY NO 14
24 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that if [Deutsche Bank National Trust Company] purchased the
26 Promissory Note and paid MERS such assignment would constitute fraudulent
27 conveyance
28
LAW OFFICES -6shyAllen Matkins leek Gamble Mallory amp Nats llP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
888664011LA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
17
18
19
21
22
23
24
26
27
28
ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
1 II INTERROGATORY NO 15
211 State all facts RELATING TO YOUR contention in the COMPLAINT
3 that lIif [Deutsche Bank National Trust Company] purchased the Promissory Note
4 and paid MERS such assignment would constitute fraudulent conveyance
INTERROGATORY NO 16
6 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
7 COMPLAINT that the DEUTSCHE BANK participated in fraud by processing
8 falsified assignments of the Deed of Trust
9 INTERROGATORY NO 17
State all facts RELATING TO YOUR contention in the COMPLAINT
11 that DEUTSCHE BANK participated in fraud by processing falsified assignments
12 of the Deed ofTrust
13 INTERROGATORY NO 18
14 IDENTIFY all DOCUMENTS RELATING TO YOUR contention in the
COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that they
16 received valid assignment of Deed ofTrust and enforceable endorsement of the
17 Promissory Note to procure payments from Plaintiff that they were not entitled to
18 receive
19 INTERROGATORY NO 19
State all facts RELATING TO YOUR contention in the COMPLAINT
21 that DEUTSCHE BANK falsely represented to Plaintiff that they received valid
22 assignment of Deed of Trust and enforceable endorsement of the Promissory Note
23 to procure payments from Plaintiff that they were not entitled to receive
24 INTERROGATORY NO 20
State all COMMUNICATIONS RELATING TO YOUR contention that in
26 the COMPLAINT that DEUTSCHE BANK falsely represented to Plaintiff that
271 they received valid assignment of Deed of Trust and enforceable endorsement of
28 LAW OFFICES -7shyAllen Matkins Leck Gamble
Mallory amp Nalels LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS888664011LA
INTERROGA TORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
17
18
19
21
22
23
24
26
27
28
ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
SARINMALUJA
By AifiN- V 8 A SALUJ
1 II the Promissory Note to procure payments from Plaintiff that they were not entitled
2 II to receive
3 IIINTERROGATORY NO 21
4 II IDENTIFY all PERSONS with knowledge of the facts RELATING TO
II YOUR contention that DEUTSCHE BANK falsely represented to Plaintiff that
6 they received valid assignment of Deed ofTrust and enforceable endorsement of
7 the Promissory Note to procure payments from Plaintiff that they were not entitled
8 II to receive
9
Dated March 252011 ALLEN MATKINS LECK GAMBLE MALLORY amp NATSIS LLP
11 ANDREW E MILLER LORAINE L PEDOWITZ
12
13
14 Attom~ys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY
16
17
18
19
21
22
23
24
26
27
28
ultW OFFICES -8shyAllen Matkins Leek Gamb Mallory amp Natsis LLP DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS
88866401ILA INTERROGATORIES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
5
10
15
20
25
PROOF OF SERVICE1
2 I am employed in the County of Los Angel es State of California I am over the age of eighteen (18) and am not a party to this action My business address is 515 South Figueroa Street
3 II Ninth Floor Los Angeles California 90071-3309
9 II Huntington Beach CA 92647 Tel 7149074182
11 111amp1 BY OVERNIGHT DELIVERY I deposited in a box or other facility regularly maintained by FedEx or delivered to a courier or driver authorized by said express service
12 carrier to receive documents a true copy of the foregoing document(s) in sealed envelopes or packages designated by the express service carrier addressed as indicated above on the
13 above-mentioned date with fees for overnight delivery paid or provided for
14 II I declare under penalty ofperjury that I am employed in the office of a member of thc bar
4 II
II
6
7
8 II
16
17
18
19
21
22
23
24
26
27
28
LAW OFFices
Allen Matkins Leek Gamble Mallory amp Natsl LLP
ofthis Court at whose direction the service was made and that the foregoing is true and correct
Executed on March 25 2011 at Los Angeles CalifQ middotX
Marcella Lrons (~ WlaquoJ (Type or print name)
On March 252011 I served the within document(s) described as
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS FIRST SET OF INTERROGATORIES TO PLAINTIFF BRIAN W DAVIES
on the interested parties in this action as stated below
Garry L Harre Attorney for Plaintiff Global Capital Law PC 17111 BeachBl Stel00
DEFENDANT DEUTSCHE BANK NATIONAL TRUST COMPANYS 888664011LA INTERROGATORlES TO PLAINTIFF
