Request for Production of Documents Foreclosure

IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 09-00xxxx-CA-(13)

WELLS FARGO BANK, N.A.
Plaintiff,
vs.

A.M and M.A., et. al.
                  Defendants.
__________________________________________________/

DEFENDANT’S, A.M and M.A., REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF

The Defendants, A.M and M.A., through the undersigned attorney, requests the Plaintiff, WELLS FARGO BANK, N.A., to produce, pursuant to Fla.R.Civ.P. 1.350, the following:

1) Loan file pertaining to the subject note and mortgage, including any underwriting documents, underwriter’s notes, appraisal of the subject property.

2) Underwriting guidelines for the loan program pursuant to which the subject loan to the defendants was approved.

3) Any documents in the loan file for A.M and M.A.setting forth or discussion why they was accepted but did not otherwise meet the underwriting guidelines.

4) Loan history, including documents which show payments made by A.M and M.A. and the allocation of such payments.

5) Documents which evidence any relationship between the Plaintiff, Wells Fargo Bank, N.A., and any forced placed insurer utilized to place insurance on the subject property, including, agreements between the insurer and Wells Fargo Bank, N.A, evidence of any compensation (including “kick-backs”) paid to Wells Fargo Bank, N.A by the insurer for any forced placed insurance during the past three years, etc.

6) Documents which evidence premium charge from the forced placed insurance and the dates for which each policy was in effect.

7) Documents which evidence payments by Plaintiff for forced placed insurance for the subject property.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on October , 2012, a true and correct copy of the foregoing was Fax: 813.251.1541; E-Mail: eservice@wolfelawfl.com to: Ron Pereira, Esq., Ronald R. Wolfe & Associates, P.L , Esq., 4919 Memorial Hwy, Ste 200, Tampa, Florida 33634-7500.

SACKRIN & TOLCHINSKY, P.A.
Attorney for Defendant(s)
2100 East Hallandale Beach Blvd./Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 458-8655
Facsimile: (954) 455-9649

By__________________________________________
ALAN D. SACKRIN, ESQ. Florida Bar No. 349070
LARRY TOLCHINSKY, ESQ. Florida Bar No 021997

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This is a sample document related to a specific set of facts and circumstances and should not be used or relied upon if any foreclosure, deficiency judgment, short sale or any other real estate matter. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique.