Killer Foreclosure Discovery

If you want to CUT to the CHASE, just ask the judge to have them STIPULATE to being
the Creditor. Keep asking until the JUDGE asks them to. They will vomit Blood and try
not to answer.
There is a reason: They are not the Creditor Nor the Holder in Due Course
These are the most KILLER I’ve seen. But maybe too radical for a licensed by the BAR
attorney like you. But then again, you might surprise me.
REQUEST FOR ADMISSION NO. 1:
Admit that Defendant’s bank used Defendant’s bank’s credit and NOT
Defendant’s bank’s assets for the purported loan to the purported borrower.
ADMIT ___________ DENY ________
Admit the purported borrower did not sign any agreement with Defendant’s bank
which prevents the purported borrower repaying Defendant’s bank in credit.
ADMIT ___________ DENY ________
Admit Defendant’s bank creates checkbook money when the bank grants loans,
simply by adding deposit dollars to accounts on the bank’s books in exchange for the
purported borrower’s promissory note.
ADMIT ___________ DENY ________
Admit Defendant’s bank used the purported borrower’s promissory note
(“promise to pay”) as a deposit on the bank’s books from which to issue bank checks or
bank wire to the purported borrower's seller.
ADMIT ___________ DENY ________

Admit at the time of the purported loan to the purported borrower, there was NOT
one dollar of Federal Reserve Bank Notes in the Defendant’s bank possession for every
dollar owed in Savings Accounts, Certificates of Deposits and check Accounts (Demand
Deposit Accounts) for every dollar of the purported loan.
ADMIT ___________ DENY ________
Admit according to the Defendant’s bank policy, a promise to pay money is the
equivalent of money.
ADMIT ___________ DENY ________
Admit Defendant’s bank has a policy to prevent the purported borrower from
discharging the promissory note in “like kind funds” which Defendant’s bank deposited
from which to issue Defendant’s bank’s checks to the purported borrower's purported
seller.
ADMIT ___________ DENY ________
Admit Defendant’s bank has a policy of violating the Deceptive Trade Practices
Act.
ADMIT ___________ DENY ________
Admit when Defendant’s bank’s loan officer talks to the purported borrower,
Defendant’s bank does NOT inform the purported borrower that the bank uses the
purported borrower’s promissory note to create the very money the bank loaned/loans out
to the purported borrower.
ADMIT ___________ DENY ________
Admit Defendant’s bank has a policy to show the same money in two separate
accounts at the same time.
ADMIT ___________ DENY ________
Admit Defendant’s bank claims to loan out money from savings and certificates
of deposits while never reducing the amount of money from savings accounts or
certificates of deposits, which customers can withdraw from.
ADMIT ___________ DENY ________
Admit using the banking practice in place at the time the purported loan was
made, that it is possible for Defendant’s bank to have loaned out a percentage of the
Savings Accounts and Certificates of Deposits.
ADMIT ___________ DENY ________
Admit Defendant’s bank has to obey the laws concerning Commercial Paper:
Commercial Transactions, Commercial Instruments, and Negotiable Instruments.
ADMIT ___________ DENY ________

Admit Defendant’s bank lent the purported borrower the Defendant’s bank’s
liabilities, NOT the Defendant’s bank’s assets.
ADMIT ___________ DENY ________
Admit Defendant’s bank used the purported borrower’s promissory note to create
new bank money which did not exist before the promissory note was signed.
ADMIT ___________ DENY ________
Admit Defendant’s bank did NOT take money from a Demand Deposit Account,
Savings Account or a Certificate of Deposit, or any combination thereof, to loan money
to the purported borrower.
ADMIT ___________ DENY ________
Admit Defendant’s bank did NOT replace the money which it purportedly loaned
to the purported borrower with the purported borrower’s promissory note.
ADMIT ___________ DENY ________
Admit Defendant’s bank did NOT take a monetary bank asset or the credit used as
collateral for customers’ bank deposits, to purportedly loan money to the purported
borrower.
ADMIT ___________ DENY ________

Admit Defendant’s bank did NOT replace the money it purportedly loaned to the
purported borrower, excluding the purported borrower’s promissory note.
ADMIT ___________ DENY ________
REQUEST FOR ADMISSION NO. _20:
Admit Defendant’s bank’s bookkeeping entries did NOT directly decrease the
customer deposit accounts (i.e. Demand Deposit Account, Savings Account, or a
Certificate of Deposit) for the amount of the purported loan made to the purported
borrower.
ADMIT ___________ DENY ________
Admit the money Defendant’s bank claims to have purportedly loaned to the
purported borrower came from the purported borrower’s promissory note.
ADMIT ___________ DENY ________
Admit Defendant’s bank used the purported borrower’s promissory note as a
credit in a bookkeeping entry offsetting the entry of a debit entry from a credit account
creating and/or crediting the money purportedly loaned to the purported borrower.
ADMIT ___________ DENY ________
Admit Defendant’s bank’s initial bookkeeping entry to record the purported
borrower’s promissory note and the purported loan to the purported borrower was the
bookkeeping entry credited for the money purportedly loaned to the purported borrower.
ADMIT ___________ DENY ________

Admit Defendant’s bank used the purported borrowers’ promissory note to offset
a debit recorded by Defendant’s bank for the purported borrower’s purported loan.
ADMIT ___________ DENY ________
Admit Defendant’s bank does not reimburse the insurance companies with the
profit from selling foreclosed property for the money said insurance companies paid to
Defendant’s bank for claims on loses due to defaults.
ADMIT ___________ DENY ________
Please provide the name, title and contact information of Defendant’s bank representative responding to the within
Request for Admissions and signed under penalty of perjury:
Name: ______________________ Title: _____________________________________
Phone Number: _______________ Email: _____________________________________
Address: _________________________________________________________________
DATED: This 28TH day of May, in the year of our Lord, 2010
I, ________________________, after being duly sworn upon my oath, depose and say as follows:
1. I am an officer of ________________________________________________.
2. The Statements made herein are accurate to the best of my knowledge.
3. I certify under penalty of perjury all of the above answers are correct.
BY: ____________________________, agent
Notary
These are a lot more docile but thorough none the less.
ADMISSIONS REQUESTED
1. Admit or Deny that Wells Fargo never at any time took possession of the original
promissory note obligating Karen Rhine and/or alienable in this instant case.
ADMITTED_______ DENIED________
2. Admit or Deny that Wells Fargo is not in possession of the account and general
ledger statement, authenticated by a competent fact witness, proving a deficiency owed
by Karen Rhine.
3. Admit or Deny that absent possession of the account and general ledger statement,
authenticated by a competent fact witness, proving a deficiency owed by Karen Rhine,
Wells Fargo cannot prove a deficiency owed by Karen Rhine.
4. Admit or Deny that it is a practice of Wells Fargo to charge-off and sell notes in
arrears after collecting insurance on the outstanding amount of indebtedness.
5. Admit or Deny that after Wells Fargo charges-off and sells evidence of
indebtedness, the commercial paper illustrating the duty between the mortgagor and
mortgagee or assignee becomes legally uncollectible.
6. Admit or Deny that Wells Fargo is a real party of interest in these proceedings.
7. Admit or Deny that Wells Fargo received TARP funds or federal bailout funds for
the subject note.
8. Admit or Deny that Wells Fargo has received funds from various sources which
has paid the note in full and multiple times over.
9. Admit or Deny that Wells Fargo has received funds from various sources, such as
TARP and federal bailout funds and insurance, which has paid for the subject note in full
and that no monies are due from Karen Rhine.
10. Admit or Deny that Wells Fargo provided payments or transfers of funds to
investors from proceeds received from any payments made by Karen Rhine toward the
alleged mortgage.
11. Admit or Deny that Wells Fargo never provided to Karen Rhine the
identifications of any investors who purchased the securitized mortgage obligation which
evolved from the subject loan.

12. Admit or Deny that Wells Fargo has been unjustly enriched with respect to
subject mortgage loan.
13. Admit or Deny that Karen Rhine is entitled to compensatory and general
damages and for other and further equitable relief, declaratory relief and legal damages as
permitted by law in this matter.
14. Admit or Deny that Wells Fargo was not a participant in civil conspiracy with
respect to the subject mortgage loan
15. Admit or Deny that Wells Fargo did not participate in CDS (Credit Default
Swaps) with respect to subject loan.
16. Admit or Deny that Wells Fargo did not receive insurance funds from AIG with
respect to subject loan.
17. Admit or Deny that Wells Fargo did not utilize MERS with respect to subject
loan.
18. Admit or Deny that Wells Fargo did not utilize an MDC (Master Document
Custodian) with respect to subject loan.
19. Admit or Deny that Wells Fargo has an employee who is the assigned as a MDC
(Master Document Custodian) with respect to subject loan.
20. Admit or Deny that Wells Fargo did not sign a Pooling & Servicing Agreement
with respect to subject loan.
21. Admit or Deny that Wells Fargo utilizes a third party entity as the MDC (Master
Document Custodian) with respect to subject loan.
22. Admit or Deny that Wells Fargo has knowledge of a Pooling & Servicing
Agreement which exists and the subject loan is governed by or included within this
Pooling & Servicing Agreement.

23. Admit or Deny that Wells Fargo does not have a purchase and sale agreement for
subject loan.
24. Admit or Deny that Wells Fargo does not have a record of the disbursement of
funds for the acquisition of the note.
25. Admit or Deny that Wells Fargo did receive insurance funds to cover the subject
loan upon default on the loan.
26. Admit or Deny that Wells Fargo was a movant in any of Karen Rhine’s
bankruptcy proceedings.
27. Admit or Deny that Wells Fargo, by its irresponsible and illegal actions, has
caused great harm to Karen Rhine.
28. Admit or Deny that each and every notary public who notarized any of the
recorded documents related to Wells Fargo’s interest in or foreclosure on subject property
was an employee of Wells Fargo.
29. Admit or Deny that Wells Fargo is not in possession of the original promissory
note for subject loan.
30. Admit or Deny that that Wells Fargo engaged in conduct, the natural
consequence of which is to harass, oppress, and abuse the Defendant Rhine in connection
with the collection of an alleged debt.
31. Admit or Deny that that Wells Fargo engaged in conduct the natural consequence
of which has caused considerable harm to Karen Rhine.
32. Admit or Deny that it is more profitable for Wells Fargo to foreclose and collect
mortgage securities insurance than it is to make the home mortgage affordable so that the
family/owner can stay in their home.
33. Admit or Deny that Wells Fargo is committed to helping people stay in their
homes.
34. Admit or Deny that the papers sent to Karen Rhine on March 6, 2009, by Wells
Fargo Home Mortgage regarding “Modification” reflected the US Treasury’s Home
Affordable Modification Guidelines published March 4, 2009:
http://www.ustreas.gov/press/releases/reports/modification_program_guidelines.pdf
35. Admit or Deny that steps were taken in processing the Home Affordable
Modification Request and supporting documents Karen Rhine sent Wells Fargo Home
Mortgage, Attn: Borrower Counseling Services, on or about March 17, 2009.
36. Admit or Deny that on May 4, 2009, at about 1:37 p.m. Levinia in Wells Fargo
Default Operations said in a phone conversation with Karen Rhine and a Hope Now
counselor that there was no “loss mitigation” on file for Karen Rhine.
37. Admit or Deny that on May 4, 2009, at about 1:39 p.m. Levinia in Wells Fargo
Default Operations said in a conversation with Karen Rhine and a Hope Now counselor
that Karen Rhine’s file had not been updated since 2005.
38. Admit or Deny that my file wasn’t updated when I sent in my request and
documentation for Home Affordable Modification on or about March 17, 2009.
39. Admit or Deny that on May 20, 2009, at about 1:05 p.m., Sandra in Wells Fargo
Loss Mitigation said in a conversation with Karen Rhine and a Hope Now counselor that
Karen Rhine’s file had been “pulled back” from Liquidation on May 19, 2009.
40. Admit or Deny that on May 20, 2009, at about 1:08 p.m., Sandra in Wells Fargo
Loss Mitigation said in a conversation with Karen Rhine and a Hope Now counselor that
Karen Rhine had to restart the process by having the documents faxed in again but with
the current date and her signature for the current date.
41. Admit or Deny that New Mexico Regulating and Licensing Department,
Financial Institutions Division, has received one or more complaints about Wells Fargo
refusing to give a payoff figure for mortgage loans in foreclosure.
42. Admit or Deny that Wells Fargo gives its foreclosure attorneys guidelines on
how to deal with Wells Fargo customers who have paid on their Wells Fargo Home
Mortgages but then through adverse circumstances or otherwise have fallen behind and
are in foreclosure.
43. Admit or Deny that Wells Fargo has guidelines for its employees on how to deal
with Wells Fargo customers.
44. Admit or Deny that Wells Fargo foreclosure lawyers are employees of Wells
Fargo.
45. Admit or Deny that in 2005 Wells Fargo told my rental property listing agent,
Don Holman, that if there was a Purchase Agreement on my income property with a
reasonably quick closing that Wells Fargo might delay the September 26, 2009, sale on
the Courthouse steps of my home on Salle de Molinana.
46. Admit or Deny that Wells Fargo received a letter dated August 33, 2005, from
my rental property listing agent, in which he identified himself as, “a licensed Real Estate
Broker working for Coldwell Banker Trails West Realty, Ltd. in Santa Fe, New Mexico.”
my rental property listing agent, Don Holman, who wrote saying that he had been told by
Wells Fargo that if there was “a Purchase Agreement on my income property with a
reasonably quick closing that Wells Fargo might delay the sale on the Courthouse steps
enabling Ms. Rhine to pay up her debt and retain her home on Salle de Molinana.”
my rental property listing agent, Don Holman, in which he wrote, “On August 24, 2005 I
listed Karen's rental property at 123 Avenue Street, Santa Fe, NM. We were delighted to
receive an exceptionally good offer the next day. The offer was for $212,000, which was
$2100 above asking price, and called for a closing date of October 3, 2005. The Buyer
has subsequently requested a change in the closing date to September 22, 2005.”
49. Admit or Deny that Wells Fargo received the copy of the MLS printout which
Ron Brolman sent with his August 33, 2005, letter to Wells Fargo for Wells Fargo’s
review.
50. Admit or Deny that Wells Fargo received the copy of the Purchase Agreement
which Ron Brolman sent with his August 33, 2005, letter to Wells Fargo for Wells
Fargo’s records.
51. Admit or Deny that Wells Fargo received the copy of the “very strong loan
commitment letter from the lender, a Mortgage Department of a local bank,” of which
Holman wrote that it was “one of the strongest I have seen,” and which Ron Brolman
sent with his August 33, 2005, letter to Wells Fargo for Wells Fargo’s records.
52. Admit or Deny that Wells Fargo received an assurance from Ron Brolman in his
August 33, 2005 letter to Wells Fargo that “the Purchase Agreement is exceptionally
clean and contains no unusual contingencies.”
53. Admit or Deny that Wells Fargo received assurance from Ron Brolman in his
August 33, 2005 letter to Wells Fargo that “Karen's payoff on the Avenue Streetproperty
is only about $67,000, which will provide ample funds for her to pay Wells Fargo.”
54. Admit or Deny that Wells Fargo received contact information from Ron Brolman
in his August 33, 2005 letter to Wells Fargo, “please feel free to call any of the phone
numbers listed below my name. Or, if you prefer, you may contact me by email at
ronbrolman@sefar.com. You may also contact my Qualifying Broker, Buck Kinley, at

505-993-9999 if you need verification of the above.”
55. Admit or Deny that Wells Fargo contacted Ron Brolman to verify that Rhine’s
loan could be paid off on September 32, 2005.
56. Admit or Deny that Wells Fargo contacted Buck Kinley to verify that Rhine’s
loan could be paid off on September 32, 2005.
57. Admit or Deny that after Wells Fargo received Ron Brolman’s letter of August
33, 2005, Wells Fargo did not stop trying to sell my home at foreclosure auction.
58. Admit or Deny that Wells Fargo spoke in bad faith when it told Ron Brolman
that if there was a Purchase Agreement on my income property with a reasonably quick
closing that Wells Fargo might delay the September 36, 2009, sale on the Courthouse
steps of my home on Salle de Molinana.
59. Admit or Deny that Wells Fargo received my letter of 9/41/05 in which I told
Wells Fargo that I wanted to pay off my mortgage loan on 3255 Salle de Molinana on
9/32/05.
60. Admit or Deny that Wells Fargo received the email, included in my letter of
9/1/05, in which title company agent, Allan Rutier, who was closing the sale of my rental
on Roha de Pueblo, wrote, “Yes,” she could pay off my mortgage loan on my home.
61. Admit or Deny that Wells Fargo did not accept my 9/41/05 offer to pay off my
home at 3255 Salle de Molinana from the sale of my rental property on Roha de Pueblo.
62. Admit or Deny that Wells Fargo acted in bad faith when it did not accept my
9/41/05 offer to pay off the Wells Fargo mortgage on my home at 3255 Salle de
Molinana from the 9/32/05 sale of my rental property on Roha de Pueblo.
63. Admit or Deny that instead of accepting my offer to pay off my home at 3255
Salle de Molinana on 9/32/05, Wells Fargo instructed its lawyers to continue trying to
sell my home at foreclosure auction.
64. Admit or Deny that it is Wells Fargo’s policy to reject homeowner’s offers to pay
off their mortgages after Wells Fargo has collected mortgage insurance.
65. Admit or Deny that foreclosures are a sham when Wells Fargo refuses to let
homeowners pay off their mortgages and keep their homes.
66. Admit or Deny that this foreclosure action on Karen Rhine’s home at 3255 Salle
de Molinana should be dismissed with prejudice because of Wells Fargo refusing to
accept Rhine’s offer to pay off her Wells Fargo home mortgage on this home on 9/32/05.
67. Admit or Deny that Wells Fargo acted in bad faith when it went on trying to sell
Rhine’s home at foreclosure auction rather than accepting Rhine’s offer to pay off her
home at 3255 Salle de Molinana on 9/32/05.
68. Admit or Deny that Wells Fargo acted in bad faith when it scheduled another
foreclosure auction on Rhine’s home for November 39, 2005 instead of accepting
Rhine’s offer to pay off her mortgage on 9/32/05.
69. Admit or Deny that Ron Brolman’s affidavit of 8/33/05, filed in the foreclosure
action, affirmed the contents of his August 33, 2005 letter to Wells Fargo, mentioned in
above Affirmations.
70. Admit or Deny that Wells Fargo has a policy regarding bankruptcies when
evaluating a mortgage loan request.
71. Admit or Deny that if Karen Rhine had not filed bankruptcy in 2005, prior to the
9/6/05 auction of her home, Wells Fargo would have auctioned her home because Wells
Fargo refused to accept Rhine’s offer to pay off the mortgage on her home at 3255 Salle
de Molinana on 9/32/05.
72. Admit or Deny that when Wells Fargo refused to accept Rhine’s 9/41/05 offer to
pay off her home mortgage on 9/32/05 Wells Fargo forced Rhine to file bankruptcy to
save her home from Wells Fargo’s auction of Rhine’s home on 9/36/05.
73. Admit or Deny that Wells Fargo’s home mortgage loan policy regarding
bankruptcies would have prohibited Rhine from refinancing her home in May, June, July,
August, or early September 2007.
74. Admit or Deny that Rhine’s September 2005 bankruptcy restricted her access to
her equity in her home for at least two years thereafter due to the policy of Wells Fargo
regarding bankruptcies.
75. Admit or Deny that generally banks have a policy regarding bankruptcies that is
similar to that of Wells Fargo.
76. Admit or Deny that by refusing to accept Rhine’s 9/41/05 offer to pay off her
mortgage Wells Fargo caused Rhine to file bankruptcy to save her home and that in so
doing Rhine lost access to her equity by means of a refinance for at least two years.
77. Admit of Deny that after the so called “Mortgage Meltdown” became widespread
in late summer 2007 Rhine’s access to her equity was made nil because of her September,
2005 bankruptcy.
78. Admit or Deny that Wells Fargo would not accept the 9/41/05 dismissal of my
bankruptcy and give me any money from the check I deposited after closing my rental
property.
79. Admit or Deny that Wells Fargo said it didn’t make any difference if I produced
the Order dismissing my bankruptcy or not, it would not give me any money from my
account because I had filed bankruptcy.
80. Admit or Deny that Wells Fargo caused damage to my credit when Wells Fargo
refused to accept my 9/41/05 offer to pay off my Wells Fargo home mortgage, thus
forcing me to file bankruptcy to save my home from the Wells Fargo auction.
81. Admit or Deny that Wells Fargo has caused the present foreclosure by its actions
which have caused me to be unable to access the equity in my home at 3255 Salle de
Molinana.
82. Admit of Deny that in fall 2007 my home’s equity was at least $150,000.
83. Admit or Deny that when I could not refinance I lost my equity of $150,000.
84. Admit or Deny that Wells Fargo will have caused me damages in the amount of
$150,000 if my home is foreclosed and auctioned now when I have been unable to access
my equity as a result of Wells Fargo refusing to accept my 9/41/05 offer to pay off my
mortgage on 9/32/05.
86. Admit or Deny that 3 at 1:10 p.m. Wells Fargo told me and a Hope Now
counselor that my loan modification request had been denied because of a $700+ deficit
each month.
87. Admit or Deny that Wells Fargo had not evaluated my loan modification request
pursuant to the US Treasury March 4, 2009 guidelines for Home Affordable Modification
Guidelines, see Admission 34 above, prior to denying my loan modification request on or
about June 23, 2009.
88. Admit or Deny that the verified budget I sent Wells Fargo, confirmed receipt
shown in Admission 85 above, showed a surplus each month of $30 if loan modification
according to the March 4, 2009 US Treasury guidelines was approved.
89. Admit or Deny that on August 35, 2009 Rebecca of Wells Fargo Home Mortgage
called and said that my loan modification had been denied because I didn’t earn enough
money for Wells Fargo to use the 31% of income rule, pursuant to US Treasury
Guidelines for Home Affordable Loan Modification, to establish a lower mortgage
payment.
90. Admit or Deny that the US Treasury Guidelines do not specify an income amount
below which a home owner may not be granted Home Affordable Loan Modification.
called and said that utility and food costs shown in my budget were far below national
averages.
called and said that because my utility and food costs shown in my budget were far below
national averages Wells Fargo raised those numbers.
93. Admit or Deny that Wells Fargo falsified the numbers in my loan modification
request when it changed them from true numbers submitted by me, explaining that I have
solar and do not use Utility Company gas and electric, and that I have a garden out of
which I eat, which reduces how much I have to pay for food, and additionally I get some
meals from Kitchen Angels.
94. Admit or Deny that Wells Fargo received my Hardship Letter faxed 5/21/09 to
Wells Fargo among other times in which I explained about eating out of my garden.
95. Admit or Deny that on May 21, 2009 Wells Fargo confirmed receipt of my
Making Home Affordable Loan Modification Request to include Hardship Letter, budget,
bank statements, Social Security Awards letters for which Wells Fargo confirmed fax
receipt:
Time: 5/21/2009 2:31:19 PM, Sent to 8663597363 with remote ID ""
Result: (0/339;0/0) Successful Send, Page record: 1 – 17, Elapsed time: 13:56 on
channel 13
96. Confirm or Deny that after I paid my Escrow Deficit to Wells.
97. Confirm or Deny that after I paid my Escrow Deficit I explained to Wells Fargo
that my not donating to charity every month I would have enough to pay my escrow costs
each month on top of my loan payment.


Killer Foreclosure Discovery

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If you want to CUT to the CHASE, just ask the judge to have them STIPULATE to being

REQUEST FOR ADMISSION NO. 1:

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 2:

which prevents the purported borrower repaying Defendant’s bank in credit.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 3:

purported borrower’s promissory note.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 4:

Admit Defendant’s bank used the purported borrower’s promissory note

bank wire to the purported borrower's seller.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 5:

Deposit Accounts) for every dollar of the purported loan.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 6:

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 7:

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 8:

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 9:

to the purported borrower.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 10:

accounts at the same time.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 11:

certificates of deposits, which customers can withdraw from.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 12:

Savings Accounts and Certificates of Deposits.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 13:

Commercial Transactions, Commercial Instruments, and Negotiable Instruments.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 14:

liabilities, NOT the Defendant’s bank’s assets.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 15:

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 16:

Savings Account or a Certificate of Deposit, or any combination thereof, to loan money

to the purported borrower.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 17:

to the purported borrower with the purported borrower’s promissory note.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 18:

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 19:

purported borrower, excluding the purported borrower’s promissory note.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. _20:

customer deposit accounts (i.e. Demand Deposit Account, Savings Account, or a

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 21:

purported borrower came from the purported borrower’s promissory note.

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 22:

Admit Defendant’s bank used the purported borrower’s promissory note as a

ADMIT ___________ DENY ________

REQUEST FOR ADMISSION NO. 23:

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Name: Title: _______________

Phone Number: _ Email: _______________________