IN THE CURCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION F UNIFORM

CASE NUMBER 2920-12-CA-004879-A001-HC Bank of America, N.A., PLAINTIFF, and/or its predecessor(s) in interest Vs. Donna Lee Hunter, DEFENDANT 1

NOTICE OF FIRST REQUEST FOR INTERROGATORIES

COMES NOW, I, Donna Lee Hunter, pro-se, in forma pauperis, and Defendant 1, in this case, request that the Plaintiff, Bank of America, and/or its predecessor(s) in interest, provide answers to the following interrogatories:

(1) State the indicated information about each person actually answering these interrogatories: a. What is your full legal name? b. What is your business address? c. What is your resident address? d. What is your occupation and job title?

(2) What is the relationship of Bank of America, and/or its predecessor(s) in interest NA to Bank of America Home Mortgage?

(3). What is the relationship of Bank of America NA to Bank of America Securities?

(4). What is the relationship of Bank of America Home Mortgage to Bank of America Securities?

(5). Explain how Bank of America mortgages are securitized?

(6). Are or were Bank of America mortgages traded as derivatives and/or swaps?

And, if so, provide the total value of those transactions for each of the last seven years.

(7). What is Bank of Americas leverage ratio on mortgage securities? If it has changed, please provide the leverage ratio for each of the last seven years?

(8) Did/does Bank of America have mortgage securities insurance through AIG or another insurance provider?

(9) Can Bank of America provide the amount of insurance covering mortgage securities that has been collected/paid to any division of Bank of America in each of the last seven years? And if so, provide such amounts.

(10). Is it more profitable for Bank of America 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?

(11) Can Bank of America state the names of the person(s) involved in the underwriting of the subject loan, where underwriting refers to any person who made representations, evaluations or appraisals of value of the home, value of the security instruments, ability of the borrower to pay including:

a. their names, b. addresses, c. current employment status, d. phone number, and e. email addresses. If so, provide such names.

(12) Can Bank of America state the names, addresses, phone numbers and email addresses of any persons who had any contact with ANY third party regarding:

a. the securitization, b. sale, c. transfer, d. assignment, e. hypothecation, f. or any document or agreement, oral, written or otherwise,

that would effect the funding of the subject loan, the closing of the subject loan, the receipt of money from ANY third

party in a transaction that referred to the subject loan. If so, provide a. such names, b. addresses, c. phone numbers, and d. email addresses.

(13) Can Bank of America state the names, addresses, companies, subsidiary phone numbers and email addresses of any person known or believed by anyone at Bank of America, and/or its predecessor(s) in interest to have received either physical possession of the note, the mortgage, or any document that refers to or incorporates terms regarding the securitization, sale, transfer, assignment, hypothecation, or any document or agreement, oral, written, or otherwise, that would effect or involve

a. The appraisal of the subject property b. The funding of the subject loan c. The closing of the subject loan d. The management of any trust e. The receipt of money from a third party in any transaction that referred to the subject loan
f. The disbursements of any loan funds?

If so, please state such information.

(14) Can Bank of America provide a chain of custody of the mortgage from its inception to the current holder, Bank of America, and/or its predecessor(s) in interest. include a. the name, b. address, c. company, d. subdisiary phone number, and e. email address of any persons known or believed by anyone at Bank of America, and/or its predecessor(s) in interest to have received in this chain of custody, either physical possession of the note, the mortgage, or any document that refers to or incorporates terms regarding the securitization, sale, transfer, assignment, hypothecation, or any document or agreement, oral, written, or otherwise. If so,

(15) Explain how Bank of America, and/or its predecessor(s) in interest made the deal with the original or any subsequent mortgage company with respect to the subject loan or subject mortgage.

(16) Explain the circumstances where Bank of America, and/or its predecessor(s) in interest received the original promissory note. Include a. the institution and the name, b. address, c. company, d. subsidiary phone number and e. email address

of any person known or believed by to be party of this process who played any part in the transfer of the original note or mortgage.

(17) Will Bank of America, and/or its predecessor(s) in interest claim that the original promissory note to be lost or destroyed? If so, provide a detailed explanation of how this occurred, the date it occurred, and who was the last person to have possession of the original promissory note. Also, provide a. the name, b. address, c. company,

d. subsidiary phone number and e. email address of this individual.

(18) Can Bank of America produce a copy of an allonge or other paper showing a legal and valid assignment to Bank of America, and/or its predecessor(s) in interest of the promissory note obligating this Defendant, Donna Lee Hunter and/or alienable in this instant case? If so, please explain why.

I certify that a copy of this NOTICE of first REQUEST of INTERROGATORIES was mailed to Shapiro, Fishman, and Gache, LLP, 4630 Woodland Corporate Boulevard, Suite 100, Tampa, FL, 33614, by US MAIL on or before Tuesday, May 8, 2012, before 5:00PM ET.

With respect to and for this Court,

Donna Lee Hunter

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