Home – Foreclosure Defense – Pleadings Main Index

Third Request for Production of Documents

IN THE CIRCUIT COURT OF THE
20TH JUDICIAL CIRCUIT IN AND
FOR COLLIER COUNTY, FLORIDA

DEUTSHCE BANK NATIONAL TRUST CASE NO: 07-xxxx-CA
COMPANY, AS TRUSTEE FOR MORGAN
STANLEY ABS CAPITAL I, INC., TRUST
2006-HE6, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2006-HE6,
Plaintiff,
vs.
D.O.
et. al.,
Defendant.
__________________________________/

DEFENDANTS’ THIRD REQUEST FOR PRODUCTION TO PLAINTIFF

The Defendants, D.O., by and through their undersigned attorney and requests the Plaintiff, DEUTSHCE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC., TRUST, 2006-HE6, MORTGAGE PASS-THROUGH, CERTIFICATES, SERIES 2006-HE6, to produce, pursuant to Fla.R.Civ.P. 1.350 to the Law Office of Sackrin & Tolchinsky, the following:

1. Copy of the note involved in this case and any endorsement of the note.

2. Copy of a the mortgage in this case and any endorsement of the mortgage. 

3. A copy of any allonges applicable to this case. 

4. The appraisal of the subject property involved in this case utilized by the lender prior to the purchase of the subject property. 

5. A copy of the trust agreement pertaining to the creation of MORGAN STANLEY ABS CAPITAL I, INC., TRUST, 2006-HE6, MORTGAGE PASS-THROUGH, CERTIFICATES, SERIES 2006-HE6.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on June 23, 2011 a true and correct copy of the foregoing was faxed[813] 221-9171,emailed: rweeks@albertellilaw.com and mailed to: Ryan Weeks, Esq., Albertelli Law, P.O. Box 23028, Tampa, FL 33623 [Attorneys for Plaintiff] and Christopher N. Davies , Esq., Swalm, Bourgeau & Davies, 2375 Tamiami Trail North, #308, Naples, FL 43483 [Attorney for Sherwood V., Inc.] 

SACKRIN & TOLCHINSKY
Attorney for Defendants
2100 East Hallandale Beach Blvd./Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649

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

/kb

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.