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CAUSE NO.

2011-36476
MARY ELLEN WOLF AND
DAVID WOLF, on behalf of themselves and
all others similarly situated,
v.
WELLS FARGO BANK, N.A.,
AS TRUSTEE FOR CARRINGTON
MORTGAGE LOAN TRUST, TOM
CROFT, NEW CENTURY MORTGAGE
CORPORATION, AND CARRINGTON
MORTGAGE SERVICES, LLC.

IN THE DISTRICT COURT OF

HARRIS COUNTY, TEXAS

151ST JUDICIAL DISTRICT

PLAINTIFF MARY ELLEN WOLFS


FIRST SET OF INTERROGATORIES
TO DEFENDANT TOM CROFT
TO:

Defendant TOM CROFT, by and through his attorney of record, Thomas D. Pruyn, PRUYN
LAW FIRM, PLLC, 2616 South Loop West, Ste. 590, Houston, TX 77054.
Plaintiff Mary Ellen Wolf serves the following First Set of Interrogatories to Defendant

Tom Croft pursuant to rule 197 of the TEXAS RULES

OF

CIVIL PROCEDURE. Defendant

is advised that the responses to the requests must be served upon the
undersigned counsel within thirty (30) days following service. No extensions
of time with respect to the responses shall be valid unless such agreement is
set forth in writing and signed by counsel for Plaintiff.
governed by the definitions and instructions that follow.

This document is

ATTORNEY FOR PLAINTIFF

CERTIFICATE OF SERVICE
By the execution of my signature below, I certify that a true and correct copy of the
foregoing document has been served to the following parties on the 16th day of May, 2012
pursuant to rule 21(a) of the TEXAS RULES OF CIVIL PROCEDURE:
Mr. Thomas D. Pruyn
PRUYN LAW FIRM, PLLC
2616 South Loop West, Ste. 590
Houston, TX 77054
Attorney for Defendants,
Wells Fargo Bank N.A., as Trustee
For Carrington Mortgage Loan Trust,
Tom Croft, New Century Mortgage
Corporation and Carrington
Mortgage Services, LLC

Via Certified Mail


#7011-2000-0001-1177-5612

Mr. Peter C. Smart


CRAIN CATON & JAMES, P.C.
Five Houston Center, 17th Floor
1404 McKinney, Suite 1700
Houston, TX 77010
Attorney for Defendants,
Wells Fargo Bank N.A., as Trustee
For Carrington Mortgage Loan Trust,
Tom Croft, New Century Mortgage
Corporation and Carrington
Mortgage Services, LLC

Via Certified Mail


#7011-2000-0001-1177-5605

DEFINITIONS AND INSTRUCTIONS


1. Answer each request for documents separately by listing the documents and by
describing them as defined below. If documents produced in response to this request are
numbered for production, in each response provide both the information that identifies
the document and the documents number.
2. For a document that no longer exists or that cannot be located, identify the document,
state how and when it passed out of existence or could no longer be located, and the
reasons for the disappearance. Also, identify each person having knowledge about the
disposition or loss of the document, and identify any other document evidencing the lost
documents existence or any facts about the lost document.
A.

When identifying the document, you must state the following:


I.
II.
III.

The nature of the document (e.g., letter, handwritten note).


The title or heading that appears on the document.
The date of the document and the date of each addendum, supplement, or
other addition or change.
IV. The identities of the author, signer of the document, and person on whose
behalf or at whose request or direction the document was prepared or
delivered.

b. When identifying the person, you must state the following:


i. The full name.
ii. The present or last known residential address and residential telephone
number.
iii. The present or last known office address and office telephone number.
iv. The present occupation, job title, employer, and employers address.
3. Wells Fargo, you and your mean and refer to Defendant Wells Fargo Bank, N.A.,
and all other natural persons, businesses, legal entities, agents, representatives, officers,
directors, employees, partners, corporate agents, subsidiaries, affiliates, or any other
person acting in concert with Defendant or under Defendants control, whether directly or
indirectly, including any attorney.
4. you and your mean and refer to Defendant Tom Croft, and all other natural persons,
businesses, legal entities, agents, representatives, officers, directors, employees, partners,
corporate agents, or any other person acting in concert with Defendant Tom Croft or
under his control, whether directly or indirectly, including any attorney.
5. Plaintiff and Plaintiffs means and refers to Plaintiff Mary Ellen Wolf and Plaintiff
David Wolf, their representatives, and all other natural persons or businesses or legal
entities acting or purporting to act for or on their behalf.

DEFINITIONS & INSTRUCTIONS

6. Document is to be interpreted broadly and includes any original, reproduction or copy


of any kind, typed, recorded, graphic, printed, written or documentary, including without
limitation, correspondence, memoranda, calendars, desk files, interoffice
communications, notes, diaries, contracts, documents, drawings, plans, specifications,
estimates, inventories, vouchers, permits, written ordinances, minutes of meetings,
invoices, billings, checks, reports, studies, telegrams, notice of telephone conversations,
sales receipts and notes of any and all communications and every other means of
recording any tangible thing, any form of communication of representation, including
letters, words, pictures, sounds or symbols, or combinations thereof in your possession,
custody, or control.
7. Possession, custody, or control of an item means that the person either has physical
possession of the item or has a right to possession equal or superior to that of the person
who has physical possession of the item.
8. Statement means (i) a written statement signed or otherwise adopted or approved by
the person making it, or (ii) a stenographic, mechanical, electronic, or other type of
recording, or any transcription thereof which is a substantially verbatim recital of a
statement made by the person and contemporaneously recorded.
9. Person means any natural person, corporation, firm, association, partnership, joint
venture, proprietorship, governmental body, or any other organization, business, or legal
entity, and all predecessors or successors in interest.
10. Mobile device means any cellular telephone, satellite telephone, pager, personal digital
assistant, handheld computer, electronic rolodex, walkie-talkie, or any combination of
these devices.
11. Contract means the agreement that is the subject of this lawsuit, i.e. the Texas Home
Equity Adjustable/Fixed Rate Note attached to this request for production of documents
as Exhibit 1 and the Texas Home Equity Security Instrument attached to this request for
production of documents as Exhibit 2.
12. Home or Property means the real property commonly known as 6404 Buffalo
Speedway, Houston, Texas 77005.
13. Lawsuit refers to this lawsuit, Cause No. 2011-36746, in the 151 st District Court of
Harris County, Texas.
14. Foreclosure Lawsuit Against Plaintiffs means and refers to Cause No. 2011-08930;
In Re: Order For Foreclosure Concerning Mary Ellen Wolf David Wolf 6404 Buffalo
Speedway, Houston, Texas 77005; filed by Defendant Wells Fargo Bank, N.A. on
February 11, 2011 in the 151st District Court of Harris County, Texas.

DEFINITIONS & INSTRUCTIONS

ii

15. Foreclosure means the legal process by which an owners legal right to a property is
terminated. Typically involves a forced sale of the property at public auction, including
any foreclosure authorized by the TEXAS RULES OF CIVIL PROCEDURE.
16. Mortgagee means grantee, beneficiary, owner or holder of a security instrument, a
book entry system or, if the security interest has been assigned of record, the last person
to whom the security interest has been assigned of record pursuant to Section 51.0001(4)
(A), (B) and (C) of the Texas Property Code.
17. Mortgage means and refers to any and all mortgage loans related to the Plaintiffs
Home located at 6404 Buffalo Speedway, Houston, Texas 77005.
18. Lender means and includes any owner or holder of a Mortgage loan related to the
Plaintiffs Home located at 6404 Buffalo Speedway, Houston, Texas 77005.
19. Beneficiary means and includes any owner or holder of a Mortgage loan related to the
Plaintiffs Home located at 6404 Buffalo Speedway, Houston, Texas 77005.
20. Deed of Trust means any document that pledges real property in order to secure a
loan, including any document that embodies the agreement between a lender and a
borrower to transfer an interest in the borrowers property to a neutral third party, a
trustee, or other entity, to secure the payment of a debt owed by the borrower.
21. Recorded means any document recorded in the real property records in the United
States.
22. Assignment means the act of transferring to another all or part of ones property,
interest, or rights. A transfer or making over to another of the whole of any property, real
or personal, in possession or in action, or of any estate or right therein. It includes
transfers of all kinds of property, including negotiable instruments. The transfer by a
party of all of its rights to some kind of property, usually intangible property such as
rights in a lease, mortgage, agreement of sale or a partnership. Tangible property is more
often transferred by possession and by instruments conveying title such as a deed or a bill
of sale (see Blacks Law Dictionary, Sixth Edition, 1990, page 119).
23. Assignment of Mortgage means any written instrument evidencing the transfer of a
mortgage from one mortgagee, person, or lender to another (see The Arnold
Encyclopedia of Real Estate, 1978).
24. Valid Assignment of Mortgage means having legal strength or force, executed with
proper formalities, incapable of being rightfully overthrown or set aside; founded on truth
of fact; capable of being justified; supported, or defended; not weak or defective; of
binding force; legally sufficient or efficacious; and authorized by law. As distinguished
from that which exists or took place in fact or appearance, but has not the requisites to
enable it to be recognized and enforced by law (see Blacks Law Dictionary, Sixth
Edition, 1990, page 1550).
DEFINITIONS & INSTRUCTIONS

iii

25. Missing Assignment of Mortgage means there is/are gap(s) in the chain of title from
the originating lender to the purported current mortgagee. These gaps are places where, if
another party was assigned the borrowers loan at some a point in time, there should have
been an assignment of mortgage executed.
26. Invalid Assignment of Mortgage is one that purports to connect or attempt to
complete a chain of title through false statement(s), misrepresentation(s) or omission(s)
of material fact(s) in order to deceive or defraud.
27. Fraudulent Assignment of Mortgage means an invalid assignment that was prepared
and/or executed by a natural person who knowingly and willfully created the document
for use in commerce with the knowledge and intention of deceiving or defrauding the
public or with willful disregard for the truth which can form the basis for imputed
knowledge.
28. Mortgage Electronic Registration Systems, Inc. or MERS means the national
electronic database that tracks changes in mortgage servicing rights and beneficial
ownership interests in loans secured by residential real estate. The MERS System is a
wholly-owned subsidiary of MERSCORP Holdings. Its sole purpose is to serve as
mortgagee in the land records for loans registered on the MERS System and MERS
Commercial.
29. With respect to means with regard to, respecting or concerning, to bring into or
establish by association, connection or relation, either direct or indirect. It includes
alluding to, responding to, concerning, connected with, commenting on, regarding,
discussing, describing, evidencing, or pertaining to all facts and issues giving rise to
Plaintiffs last filed Petition.
30. Settlement, as used herein, means (a) an oral or written, disclosed or undisclosed
agreement, bargain, contract, settlement, partial settlement, limited settlement,
arrangement, deal, understanding, loan arrangement, credit arrangement, contingent
settlement, limitation on the amount of liability or judgment, or a promise by or between
plaintiff and any defendant or between any defendant herein whereby plaintiff or
defendant have in any way released or compromised, in whole or in part, directly or
indirectly, or agreed to do so in the future, any of the matters in controversy in this
lawsuit whether before, after or during trial or before or after any jury verdict is returned
herein or a judgment is entered or rendered herein; (b) any resolution of the differences
between the plaintiff and defendant by loan to the plaintiff or any other device which is
repayable in whole or in part out of any judgment the plaintiff may recover against
defendant; (c) Mary Carter Agreements as the term is recognized under Texas Law.
31. The term or shall include the term and and the term and shall include the term
or.

DEFINITIONS & INSTRUCTIONS

iv

32. The term any shall include the term all and the term all shall include the term
any.
33. The terms relates, relate, and relating to mean pertaining to, referring to,
concerning, directly or indirectly, expressly or implicitly, the subject matter of the
specific request, supports, evidences, constitutes, consists of, or probative of, reflects,
describes, contradicts or comprises.
34. communication includes, without limitation of its generality, statements, discussions,
conversations, speeches, meetings, remarks, questions, responses, panel discussions and
symposia, whether written or oral, formal or informal, at any time or place and under any
circumstances. The term includes, without limitation of its generality, both
communications and statements which are face-to-face and those which are transmitted
by media, including, but not limited to, intercoms, telephones, television or radio.
35. Where the context herein makes it appropriate, each singular word shall include its plural
and each plural word shall include its singular, any masculine word shall include its
feminine form, and any feminine word shall include its masculine form.
36. In answering this discovery, please furnish all information available to you, including
information in the possession of your attorneys or investigators for your attorneys, and
not merely known of your personal knowledge.
37. To the extent you assert any objection to any Interrogatory or request on the basis that the
information sought is exempt or immune from discovery under the provisions of either
the TEXAS RULES OF CIVIL PROCEDURE or the TEXAS RULES OF EVIDENCE, then respond
to so much of the Interrogatory or request which you do not claim to be exempt or
immune. Moreover, with respect to each objection made on the basis that the information
sought is exempt or immune from discovery, identify the objectionable information to the
extent that such information may be later accurately described or identified for purposes
of a Court hearing regarding the objection.
38. In this document, the definition of words or expressions shall be the generally understood
meaning of the words or expressions. To assist you in preparing your answers, please
refer to the definitions provided when responding to each of these Interrogatories.
39. These requests do not seek and are not intended to seek privileged information or
documents. In the event that you withhold information or documents or object to a
request on the grounds of a privilege, identify the applicable privilege, describe the
information or documents that you claim are privileged, and identify all persons and/or
entities that have reviewed the information or documents that you allege to be privileged.

DEFINITIONS & INSTRUCTIONS

PLAINTIFF MARY ELLEN WOLFS


FIRST SET OF INTERROGATORIES
TO DEFENDANT TOM CROFT
A.

IDENTIFICATION & AUTHENTICATION INTERROGATORIES

The following identification and authentication interrogatories do not count against


Plaintiffs limit of 25 interrogatories. TEX. R. CIV. P. 190.3(b)(3).
INTERROGATORY NO. 1:
Is the Transfer of Lien document attached to these
interrogatories as Exhibit 1 a true and correct copy of the original (Bates No.s P00499P00501)?
RESPONSE:
INTERROGATORY NO. 2:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 2 a true and correct copy of the original (Bates No.s
P00013-P00014)?
RESPONSE:
INTERROGATORY NO. 3:
Is the Affidavit of Applicant document attached to these
interrogatories as Exhibit 3 a true and correct copy of the original (Bates No.s P01795P01797)?
RESPONSE:
INTERROGATORY NO. 4:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 4 a true and correct copy of the original (Bates No.s
P01801-P01802)?
RESPONSE:
INTERROGATORY NO. 5:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 5 a true and correct copy of the original (Bates No.s
P01806-P01807)?
RESPONSE:

MEWS 1ST ROGGS TO CROFT

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INTERROGATORY NO. 6:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 6 a true and correct copy of the original (Bates No.s
P01812-P01813)?
RESPONSE:
INTERROGATORY NO. 7:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 7 a true and correct copy of the original (Bates No.s
P01817-P01818)?
RESPONSE:
INTERROGATORY NO. 8:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 8 a true and correct copy of the original (Bates No.s
P01822-P01823)?
RESPONSE:
INTERROGATORY NO. 9:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 9 a true and correct copy of the original (Bates No.s
P01827-P01828)?
RESPONSE:
INTERROGATORY NO. 10:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 10 a true and correct copy of the original (Bates
No.s P01832-P01833)?
RESPONSE:
INTERROGATORY NO. 11:
Is the Affidavit of Tom Croft document attached to these
interrogatories as Exhibit 11 a true and correct copy of the original (Bates No.s P01838P01842)?
RESPONSE:
INTERROGATORY NO. 12:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 12 a true and correct copy of the original (Bates
No.s P01846-P01847)?

MEWS 1ST ROGGS TO CROFT

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RESPONSE:
INTERROGATORY NO. 13:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 13 a true and correct copy of the original (Bates
No.s P01851-P01852)?
RESPONSE:
INTERROGATORY NO. 14:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 14 a true and correct copy of the original (Bates
No.s P01856-P01857)?
RESPONSE:
INTERROGATORY NO. 15:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 15 a true and correct copy of the original (Bates
No.s P01861-P01862)?
RESPONSE:
INTERROGATORY NO. 16:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 16 a true and correct copy of the original (Bates
No.s P01866-P01867)?
RESPONSE:
INTERROGATORY NO. 17:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 17 a true and correct copy of the original (Bates
No.s P01871-P01872)?
RESPONSE:
INTERROGATORY NO. 18:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 18 a true and correct copy of the original (Bates
No.s P01876-P01877)?
RESPONSE:

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INTERROGATORY NO. 19:


Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 19 a true and correct copy of the original (Bates
No.s P01881-P01882)?
RESPONSE:
INTERROGATORY NO. 20:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 20 a true and correct copy of the original (Bates
No.s P01886-P01887)?
RESPONSE:
INTERROGATORY NO. 21:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 21 a true and correct copy of the original (Bates
No.s P01891-P01892)?
RESPONSE:
INTERROGATORY NO. 22:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 22 a true and correct copy of the original (Bates
No.s P01896-P01897)?
RESPONSE:
INTERROGATORY NO. 23:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 23 a true and correct copy of the original (Bates
No.s P01901-P01902)?
RESPONSE:
INTERROGATORY NO. 24:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 24 a true and correct copy of the original (Bates
No.s P01907-P01908)?
RESPONSE:
INTERROGATORY NO. 25:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 25 a true and correct copy of the original (Bates
No.s P01912-P01913)?

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RESPONSE:
INTERROGATORY NO. 26:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 26 a true and correct copy of the original (Bates
No.s P01917-P01918)?
RESPONSE:
INTERROGATORY NO. 27:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 27 a true and correct copy of the original (Bates
No.s P01922-P01923)?
RESPONSE:
INTERROGATORY NO. 28:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 28 a true and correct copy of the original (Bates
No.s P01927-P01928)?
RESPONSE:
INTERROGATORY NO. 29:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 29 a true and correct copy of the original (Bates
No.s P01932-P01933)?
RESPONSE:
INTERROGATORY NO. 30:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 30 a true and correct copy of the original (Bates
No.s P01937-P01938)?
RESPONSE:
INTERROGATORY NO. 31:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 31 a true and correct copy of the original (Bates
No.s P01942-P01943)?
RESPONSE:

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INTERROGATORY NO. 32:


Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 32 a true and correct copy of the original (Bates
No.s P01947-P01948)?
RESPONSE:
INTERROGATORY NO. 33:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 33 a true and correct copy of the original (Bates
No.s P01952-P01953)?
RESPONSE:
INTERROGATORY NO. 34:
Is the Verification of Application and Affidavit document
attached to these interrogatories as Exhibit 34 a true and correct copy of the original (Bates
No.s P01958-P01960)?
RESPONSE:

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B.

STANDARD INTERROGATORIES

INTERROGATORY NO. 1:
Identify each person answering these interrogatories,
supplying information, or assisting in any way with the preparation of the answers to these
interrogatories.
RESPONSE:
INTERROGATORY NO. 2:
If you have ever been convicted of a felony or a crime
involving moral turpitude, state the nature of the charge and the date and place of arrest and
conviction. See TEX. R. EVID. 404(a)(1)(B), 609(a).
RESPONSE:
INTERROGATORY NO. 3:
code.

Please list your current home address, city, state, and zip

RESPONSE:
INTERROGATORY NO. 4:
Please list any other addresses where you resided during the
ten years immediately preceding the Incident which is the subject of Plaintiffs Petition.
RESPONSE:
INTERROGATORY NO. 5:
As to each address identified in your answer to interrogatory
number 4, please state whether the address also constituted your mailing address during the
period in which you occupied that address.
RESPONSE:
INTERROGATORY NO. 6:
If you currently own and use a personal cell phone, please
provide the name of your cell phone provider, your cell phone number, and the date you began
using the cell phone provider.
RESPONSE:
INTERROGATORY NO. 7:
Please state your current drivers license number, expiration
date, and the state in which it was issued.
RESPONSE:
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INTERROGATORY NO. 8:
you were born.

Please state your date of birth, and the city and state in which

RESPONSE:
INTERROGATORY NO. 9:
educational institution.

Please list the highest degree you have received from an

RESPONSE:
INTERROGATORY NO. 10:
Please identify and list all educational institutions from
which you have received a degree or certificate.
RESPONSE:
INTERROGATORY NO. 11:
Please identify any high school you attended, the date you
graduated, and the city and state where the high school(s) are located.
RESPONSE:
INTERROGATORY NO. 12:

Please state whether you are currently employed.

RESPONSE:
INTERROGATORY NO. 13:
If your answer to interrogatory number 12 was yes, please
state the names of the company, companies, and entities where you are currently employed.
RESPONSE:
INTERROGATORY NO. 14:
If your answer to interrogatory number 12 was yes, please
describe your job duties and job description for each company where you are currently
employed.
RESPONSE:
INTERROGATORY NO. 15:
If your answer to interrogatory number 12 was yes, please
state your current rate of compensation at each company where you are currently employed.
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RESPONSE:
INTERROGATORY NO. 16:
If your answer to interrogatory number 12 was yes, please
identify the name of your immediate supervisor at each company where you are currently
employed.
RESPONSE:
INTERROGATORY NO. 17:
Please identify and list the name and address of each
employer for whom you have worked during the last five years.
RESPONSE:
INTERROGATORY NO. 18:
As to each employer for whom you have worked during the
last five years, please list and describe your job duties and job description during the course of
your employment with each employer.
RESPONSE:
INTERROGATORY NO. 19:
As to each employer for whom you have worked during the
last five years, please identify the names of your immediate supervisor.
RESPONSE:
INTERROGATORY NO. 20:

Please state your full legal name.

RESPONSE:
INTERROGATORY NO. 21:
Please list any other names which you have used, if any, and
the inclusive dates during which each name was used.
RESPONSE:
INTERROGATORY NO. 22:
Please list and describe your specialized knowledge,
training, and experience as stated in your Verification attached to these interrogatories as
Exhibit 2 (Bates No.s P00013-P00014).
RESPONSE:
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INTERROGATORY NO. 23:


Please list and describe your familiarity with the customs,
practices, and usage within the mortgage and loan servicing industry as stated in your
Verification attached to these interrogatories as Exhibit 2 (Bates No.s P00013-P00014).
RESPONSE:

MEWS 1ST ROGGS TO CROFT

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