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LAW OFFICES OFTHOMPSON & ASSOCIATES

152 South Harvard Street Hemet, California 92543

(951) 925-3808 Fax (951) 925-3239

May 25, 2011

Barry, Gardner & Kincannon

Attention: Cathy A. Knecht

2214 Faraday Avenue

Carlsbad, CA 92008

RE: Bradley v. Wells Fargo Bank, et al.

Inadequate and inappropriate responses to Special Interrogatories

Dear Ms. Knecht:

As you know, your office received Set Number One of the Special Interrogatories propounded to

HSBC Bank, USA National Association. Included were twenty-six (26) interrogatories, and noteven one was answered by you. Recently, I received the Responses prepared on behalf of HSBC,

and every single one of them contained only objections.

I have reviewed the objections and find that none of them is genuine. I would appreciate a good-faith effort at resolving some of the issues through discovery. I sincerely hope that discovery

motions will not be necessary, however, please consider this letter to be offered for meet and

confer purposes.

Please refer to Clement v. Alegre (2009) 177 Cal.App.4th 1277. This case discusses frivolous

objections being raised to interrogatories.

I have taken the interrogatories and typed in red print after each of them the substance of yourobjections. Enclosed please find the document I created using this process.

You can see that you have used irrelevancy as an objection to almost every interrogatory. In this

regard, you should understand that the Assignment of Trust Deed from MERS as nominee for

Royal Crown Bancorp to HSBC, as Trustee. is central to the cause of action seeking to cancelthe Trustees Deed Upon Sale. Every interrogatory related to the assignment is directly relevant.Included Interrogatories are 1, 2, 6, 11, 12, 13, 14, 17, 22, 25, and 26.

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You have stated that you object on the grounds of relevancy due to the fact that the interrogatorieswill not lead to admissible evidence. However, it is not necessary that the matters sought to be

discovered be admissible in evidence at trial. CCP 207.010. Associated Brewers Distr. Co. v.Superior Court(1967) 65 Cal. 2d 583, 587. For purposes of discovery, there is a liberal standard for

relevancy. Discovery should not be denied on the grounds of irrelevancy if there is a reasonable

possibility that the answers sought by a given line of questioning will lead to the discovery ofadmissible evidence or be helpful in preparation for trial. Doubts as to relevancy should be resolved

in favor of permitting discovery. Pacific Tel. & Tel. Co. v. Superior Court(1970) 2 Cal.3d 161, 173.

On several occasions, you have objected based upon assumes facts not admitted into evidence and

lacks foundation. These are evidentiary objections which might be raised at time of trial, not atthe discovery process. It is not a proper objection to an interrogatory that the interrogatory assumesa fact not in evidence. West Pico Furniture Co. v. Superior Court(1961) 56 Cal.2d 407, 421. Not

only is the objection improper, but many of the facts are indeed already placed into evidence. We

have certified copies of recorded documents, and these are already admissible evidence. Thesedocuments serve as the basis for many interrogatories.

It is proper for a party, such as Leanna Bradley, to ask what Defendants contend. A party may be

required to disclose not only the evidentiary facts but also to disclose whether he or she is making aparticular contention either about the facts or possible issues in the case. See Burke v. SuperiorCourt(1969) 71 Cal.2d 276, 281, 282. Certainly, Interrogatory 6 falls into this category.

When asked regarding Stephanie Goble and Randy LaDon Potts and whether they were employees

of HSBC on 9/28/09, you quoted a code section applying only to subpoenas. This is not a request

for production of documents and it is not a subpoena. HSBC is merely asked to answer whether

these two persons were employees, and there is no proper objection to avoid these interrogatories.

I realize that you did not want to take the time to answer the interrogatories prior to the demurrerhearing. However, there is no legal justification for your failure to do so. Please reconsider andsend proper interrogatories well before the deadline for a motion to compel further responses.

Sincerely,

Linda J. DeVore,Attorney for Leanna Bradley

cc: Client