Interrogatories Redacted

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COURT COMMON OF PLEAS OF COUNTY, PENNSYLVANIA CIVIL ACTION LAW PlaintiffV.No. INTERROGATORIES DIRECTED TO DEFENDANT PLAINTIFF BY THECOM PLAINT ONNATIONSTAR MORTGAGE, LLC DefendantsTo: Nationstar vs, Mortgage, LLCPLEASE TAKENOTICE the Plaintiff that , hereby requests the Defendant, that Nationstar Mortgage, LLC.respond the within to interrogatories the timeprovided the within by Rules the Court.Thisrequest de

Transcript of Interrogatories Redacted

COURT COMMON OF PLEAS CHESTER OF COUNTY, PENNSYLVANIA CIVIL ACTION LAW MARY ANNSMILER PlaintiffV.

No. 11-05832 INTERROGATORIES DIRECTED TO DEFENDANT PLAINTIFF BY MARY ANN SMILER THECOM PLAINT ON

NATIONSTAR MORTGAGE, LLC Defendants

To:

Mary AnnSmiler Nationstar vs, Mortgage, LLC

PLEASE TAKENOTICE the Plaintiff that Mary Ann Smiler, hereby requests the Defendant, that Nationstar Mortgage, LLC.respond the within to interrogatories the timeprovided the within by Rules the Court.Thisrequest deemed be continuing andincluding timeof trial. of is to up the

CHERI ROBINSONASSOCIATES &

D a t e : u g u s1 9 , 2 0 1 1 A t

Cheri Robinson, Esq.

1)

Is the Defendant correctly designatedby its correct legal name in this lawsuit? If the preceding answer is in the negative pleasestatethe correctlegal name of the Defendant. RESPONSE:

2)

Pleaseidentify by name, addressand contactinformation including last known address,email address,and last known telephone number every individual who assistedor took part in formulating the responses this discovery. to RESPONSE:

3)

Pleaseexplain the position of "Certifying office{' for MERS.

a.

Include with this explanationa completeexplanationof any material differencesbetweena "Certifying officer" and a Corporate Officer of MERS.

b.

Pleaseinclude in this explanationevery power or authorify granted to a "Certifying Officer" of MERS.

c.

Pleaseinclude in this explanationevery power or authority granted to a Corporate Officer of MERS.

d.

Pleaseexplain any differencesbetweenthe power granted to a"Certifying officer" and a Corporateofficer of MERS.

e.

Pleaseexplain how " Ceftifying Officers" of MERSare compensated.

t.

Pleaseexplain every role that a"Certifying offic er" plays with respectto the Corporate Governanceof MERS.

o t''

Pleasestatehow many corporate officers exist for MERS.

h.

Pleaseproduce a completelist of every Corporate Officer of MERSwhich includes their name, employer, address,presentcontact information including email and phone number(s),length of employment and office hetd by the Officer listed and summarize the scopeof the Officers powers and authority to act on behalf of MERS.

Pleasestate how many "Ceftifying Officers" exist for MERS.

l

Pleaseproduce a completelist of every "Certtfyingofficer" of MERSwho is also employed and/ or has signing authority for

Defendantwhich includes their name, employer, address,present contact inJormation including email and phone number(s), length of employment and office held by the Officer listed and summ arize the scope of the Officers powers and authorify to act on behalf of MERS.

RESPONSE:

4)

Pleasestateevery qualification that existsfor an individual to be a "Ceftifyrng Officer" ofMERS. For eachqualification listed please state:

a. b.

when that qualification was enacted, who was responsiblefor setting or creating the qualificatiory

c.

who is responsiblefor insuring that the "Certifying Officer" meetsthe qualifications.

d.

Every method which MERSand usesto verify the qualifications of its Certifying Officers.

e.

Every action that MERSundertakesto insure that the Certifying officers meet the qualifications set by MERS.

t.

Pleaseproduce any documentswhich are responsiveto this requestwhich tend to support, verify, describeor explain any of the items material to this interrogatory.

RESPONSE:

5)

Pleasestateevery method by which MERSmonitors the actionsof its Corporate Officers. For every method mentioned in the preceding answer pleaseproduce any and all documentationwhich reflects, menrorializes,describes communicatesthe results of the efforts to or monitor the actionsof MERS'sCorporateOfficers.

RESPONSE:

6)

P1ease stateevery method by which MERSmonitors the actionsof its " Ceftifying officers". For every method mentioned in the preceding answer pleaseproduce any and all documentationwhich reflects, memorializes,describes communicatesthe results of the efforts to or monitor the actionsof MERS's"Certifying Officers". RESPONSE:

7)

Pleasestate whether ar:ry "Certifying office{' of MERS is an employeeof MERS. If the answer is in the affirmative pleaseprovide a list which includes the name, last known address,last known

employer and last known contact information of every " Certrfying Officer" of MERS who is an employee of MERS. RESPONSE:

8)

Pleasestatethe name of the personwho is in possession the of promissory note in this caseand for said person pleaseprovide their name, last known address,last known employer and last known contactinformation. For said person pleaseproduce any agreements, aathotizations, powers of attorney/ agency agreementsor any other documentswhich Defendant contendsprovides the person identified with the right to act as a holder of the promissory note which is in issuein this case. RESPONSE:

9)

PleasestateMERS' understanding of the purpose of filing an assignmentof mortgage in the public land records of the Stateof Pennsylvania. RESPONSE:

10)

PleasestateDefendant'sunderstanding of who has the legal right to changethe name of the mortgageein the public land records of the state of Pennsylvania by the filing of a mortgage assignment. RESPONSE:

11)

Pleaseidentify every interestwhich MERStracks in any mortgage loan for eachinterest identified provide a full and complete explanation of that interest. RESPONSE: