Documente Academic
Documente Profesional
Documente Cultură
SBN 147715
1
LAW OFFICES OF TIMOTHY L. MCCANDLESS
2 13240 Amargosa Road
Victorville, California 92392
3
(760) 951-3663 Telephone
4
(909) 382-9956 Facsimile
5
17 ISCHMAEL O. WHITE,
18
and DOES I through X, Inclusive
19
Defendant(s).
20
21
PROPOUNDING PARTY: Defendant, ISCHMAEL O. WHITE
22
RESPONDING PARTY: Plaintiff, BLUE MOUNTAIN MORTGAGE, LLC.
23
SET NO: One
24
25
TO PLAINTIFFS AND ITS ATTORNEY OF RECORD:
26
27
28
11 1. These requests for admissions are directed toward all information known or available
12 to PLAINTIFFS, including information contained in the records and documents in
13 PLAINTIFFS’ custody or control or available to PLAINTIFFS, upon reasonable
14 inquiry. Your answer to each request for admission shall specifically deny the matter,
15 or set forth in detail the reasons why you cannot truthfully admit or deny the matter.
16 Where requests for admissions cannot be answered fully, they shall be answered as
17 completely as possible and incomplete answers shall be accompanied by a
18 specification of the reasons for the incompleteness of the answer and of whatever
19 actual knowledge is possessed with respect to each unanswered request for admission.
20 2. Each request for an admission is to be deemed a continuing one. If, after serving an
21 answer to any request for admission, an authorized officer for PLAINTIFFS obtains
22 or becomes aware of any further information pertaining to that request for admission,
23 the authorized officer for PLAINTIFFS is requested to serve a supplemental answer
24 setting forth such information.
25 3. As to every request for an admission which an authorized officer for PLAINTIFF
26 fails to answer in whole or in part, the subject matter of the admissions will be
27 deemed confessed and stipulated as fact to the court.
28
3 1. “You” and “your” include BLUE MOUNTAIN MORTGAGE, LLC. and any and all
4 persons acting for or in concert with DEFENDANT.
5 2. “Document” includes every piece of paper held in your possession or generated by you.
6
7 ADMISSIONS REQUESTED
8
20 Admit or deny that your execution of the notices and foreclosures failed to conform to the
23 Admit or deny that your execution of the notices and foreclosures failed to conform to the
26 Admit or deny that you or your agent did not contact the borrower to assess the borrowers
27 financial condition pursuant to the provisions of California Civil Code Sections 2923.5 et seq.
28
7 _____________________________
Timothy L. McCandless, Esq.
8 Attorney for Defendant,
ISCHMAEL O. WHITE
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28