Saturday, November 8, 2008

Letter To Preserve Information

“A good name is more desirable than great riches; to be esteemed is better than silver or gold.” - Proverb 22:1

Praises & Thanks be unto The Lord My God for the wisdom, knowledge and understanding on legal matter because I received countless feedbacks from folks facing foreclosure and bankruptcy around the United States as follows:

Comments: "I have been inundated with TILA questions. So I went out hunting to see if anyone had already written about it in terms that a lay person might be able to understand. What I found is shown below. I believe it to be generally correct and the citations are good citations of law. See this site for the entire write-up. It should give most lay people an idea on how to handle this and it will be valuable to your lawyer if he/she is not totally familiar with the TILA context at the following link:" http://rcxloan.com/Civil_Action_BK_Motion_14.htm. Statement made by Attorney at Law, Neil F. Garfield, M.B.A., J.D.

Pierre R. Augustin, MPA, MBA, Pro Se
Consumer Creditor and a Party In Interest
3941 Persimmon Drive, #102
Fairfax, VA 22031, Tel: 703-584-5998, Email: hdmhos@aol.com

October 23, 2008

Attorney David W. Carickhoff, Jr
Blank Rome LLP, Chase Manhattan Centre, 1201 Market Street, Suite 800, Wilmington, DE 19801 Records Custodian for New Century TRS Holding, Inc. & Attorney, Christopher M. Samis, Richards, Layton & Finger, P.A. , 920 N. King Street, Wilmington, DE 19801

CERTIFIED MAIL: 7007 3020 0002 3324 9198

Re: New Century TRS Holding, Inc., New Century Liquidating Trustee v. Pierre R. Augustin, Pro Se, Case #: 07-10416, Chapter 11

[Our justice system is not perfect. Mistakes are inevitable. However, when
New evidences are presented, the will to do good must prevail over the status quo]

Dear Attorney Carickhoff, Jr., Records Custodian for New Century, Attorneys for Non-Parties & Non-Parties Witnesses (see list of parties):

The purpose of this letter is to notify you that you may have in your possession, or under your control, certain documents and information, including electronically or digitally stored information relevant to the discovery process of the case above. In addition, you, agents, employees & Counsels for Non-Parties Witnesses and Non-Parties Witnesses themselves may have knowledge of facts relevant to matters likely to lead to admissible evidence.

The general rule of discovery is that parties may obtain information regarding any matter relevant to the subject matter involved in the pending action so long as the matter is not privileged. It is not grounds for objection that the information may be inadmissible at trial, if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.

Please keep in mind of the following:

Federal Rule 26(a)(1)(E), Federal Rule 26(a)(2), Federal Rule 26(a)(3)
Basis for Initial Disclosure; Unacceptable Excuses. A party must make its initial disclosures based on the information reasonably available to it. A party is not excused from making its disclosures because it has not fully investigated the case or because it challenges the sufficiency of another party’s disclosures or because another party has not made its disclosures.

“When discovery rights are trampled, prejudice must be presumed”
Scott v. Greenville Housing Authority, 579 S.E.2d 151, 353 S.C. 639 (S.C. App. 2003)

The filing of this letter with the Federal Courts Will Serve
As Proof of Notification to All Counsels for the Non-Parties Witnesses
and on Non-Parties Witness themselves.

1. BUSINESS RECORDS -- MISSING EVIDENCE -- SPOLIATION
“Spoliation” can be defined as the failure to preserve evidence that is relevant to pending or potential litigation (Jimenez-Sanchez v. Carribean Restaurants, L.L.C, 483 Fed.Supp.2d 140 (D. Puerto Rico 2007)). The actual keeper or custodian of the evidence is irrelevant for discovery purposes. Counsel for New Century TRS Holding, Inc., handing files and documents to New Century Liquidating Trustee’s Counsel as in this case does not shield otherwise discoverable ‘REAL’ evidence. Moreover, New Century Mortgage Corporation had a duty to preserve evidence. Thus, New Century Mortgage Corporation should have known that evidence may be relevant to future litigation as a result of Mr. Augustin’s civil suit (06-10368) and Bankruptcy matter (05-46957).

Because preservation of documents and availability for production are essential to the orderly and expeditious disposition of litigation, the inability to produce documents impedes the litigation process and merits sanctions (See in re Prudential Insurance Company of America Sales Practice Litig., 169 F.R.D. 598, 36 FED.R.Serv.3d 767 (D.N.J. 1997)). As far as electronic discovery, the producing party is obligated to search available electronic systems for the information demanded in discovery. The willful failure to comply with a discovery demand should be construed as an intentional failure as distinguished from involuntary noncompliance; no wrongful intent need be shown to impose discovery sanctions (See Smith v. City of New York, 388 Fed.Supp.2d 179 (S.D.N.Y., 2005)(Sanctions may be imposed for both intentional and negligent destruction of evidence)(Martinez v. Abbott Laboratories, 146 S.W.3d 260 (Tex. App. 2004).

The duty to preserve evidence arises only when a party knows or reasonably should know that there is a substantial chance that a claim will be filed and that evidence in its possession or control will be material and relevant to that claim)(Clark Construction Group, Inc. v. City of Memphis, 229 F.R.D. 131 (W.D., Tenn., 2005). Under the rule generally governing discovery, a party must not destroy unique, relevant evidence that might be useful to Consumer Creditor and this includes any document made by an individual likely to have discoverable information that the disclosing party may use to support its claim or defenses. The duty to preserve evidence, set forth in the rule that generally governs discovery, extends to all relevant documents from the time the trigger date passes, and continues thereafter.

If documents sought during discovery are destroyed or cannot be located, then that party must provide an explanation for the disappearance of the evidence. There are several factors that the court should utilize in determining whether or not to impose sanctions: [a] - A party destroys, [b] - discoverable matter, [c] - which that party knew or should have known and [d] - was relevant to pending, imminent or reasonably foreseeable litigation.

The following additional factors are considered: [1] - The degree of actual prejudice to the demanding party, [2]-The amount of interference with the judicial process, [3] - The culpability of the responding party, and [4] - Whether or not the responding party was forewarned about the sanctions for noncompliance.

A party has a duty to preserve evidence when that party is placed on notice that evidence is relevant to the subject litigation or when the party should have known that evidence may be relevant to future litigation. One remedy is the so-called “Missing Document Charge,” wherein the jury is specifically informed about the missing document and is told that it may infer that the missing evidence was most unfavorable to the spoliator. See Think Pink, Inc. v. Rim, Inc., 798 N.Y.S.2d 413 (N.Y.A.D., 1 Dept., 2005). Conclusively, if document are reported missing and cannot be located by the opposing counsels, parties and non-parties witnesses, Consumer Creditor will simply infer that the missing evidence was most unfavorable to them.

2. NOTICE TO PRESERVE DOCUMENTS
Pursuant to a duty imposed by law, This Notice and the applicable court rules require the preservation of all information from your Company’s computers and computer storage systems (including tapes, drives, CD’s and DVD’s), regardless of location, relating to this matter. This includes, but is not limited to, all computer files, e-mail and other electronic communications, databases, word processing documents, PDF’s, spreadsheets, calendars, telephone logs, contact information, Internet usage files, and network access information.

For purposes of this notice, the term “electronic information” includes, but is not limited to, all text files, word processing documents, presentation files such as PowerPoint, spreadsheets, e-mail files and information concerning e-mail files (including logs of e-mail, header information, and deleted files), Internet history files and preferences, graphical files in any format, databases, calendar and scheduling information, telephone logs, contact managers, computer activity logs, and all file fragments and backup files containing electronic data.

Upon receipt of this notice, you are prohibited from destroying, erasing, or over-writing any documents, emails, or other writings that relate to the lawsuit, regardless of their physical form, type or date. Extra care must be taken for electronic writings, which can be erased by the mere storage of new data. Your client should preserve and not destroy all passwords, decryption procedures, network access codes, ID names, tutorials, written instructions, decompression or reconstruction software, in addition to all other information necessary to access, view and, if necessary, reconstruct the electronic data that we will request through discovery.

You are under a legal obligation to preserve, maintain, and protect all potential relevant evidence, including electronic evidence. The failure to preserve and retain the electronic data as outlined in this notice constitutes a spoliation of evidence and may subject you to legal claims for damages in addition to evidentiary and monetary sanctions.

3. INITIAL “REQUIRED OR MANDATORY DISCLOSURES” REMINDER - [F.R.C.P. 26(a)]
According to the United States Supreme Court, the purpose behind Rule 37 of the Federal Rules of Civil Procedure was to protect the courts and opposing parties from “delaying or harassing tactics during the discovery process (Cunningham v. Hamilton County, 527 U.S. 198, 119 S.Ct. 1915, 144 L.Ed.2d 184 (1999)). An attorney filing a responsive discovery pleading on behalf of a client must certify that he or she made a reasonable effort to see to it that the client has provided all of the information requested. See Poole v. Textron, 192 F.R.D. 494 (D.Md. 2000) and Legault v. Zambarano, 105 F.3d 24 (1st Cir. 1997).

Once a motion has been filed, the opposing party may not necessarily be able to avoid its consequences, even if he or she files a late response to your discovery requests. See Greenbriar Homes, Inc. v. Builders Insurance, 615 S.E.2d 191, 273 Ga. App. 344 (2005) holding that once a motion for failure to make discovery has been filed, the opposing party may not preclude the imposition of sanctions by making a belated discovery response. Despite the late submission, the trial court was, nevertheless, required to hold a hearing to determine whether the delinquent party’s failure to respond was willful, rather than negligent.

In accordance with Rule 26(a)(1) of the Federal Rules of Civil Procedure, Consumer Creditor is reminding Counsels for New Century TRS Holding, Inc. & New Century Liquidating Trustee to provide their mandatory disclosure as follows:

This Is A Reminder To Provide ‘Initial Mandatory Disclosures’ From Previous Notice To Produce
1. In Exhibit 1, New Century Mortgage denied the mortgage application on January 22, 2004.
Please provide the name of the person who made that decision and have him or her present at the deposition. If that person is not available, please state why? Otherwise, please provide a ‘designated deponent’ [Name] & [address] that is likely to have discoverable information relevant to Consumer Creditor’s claims as per FRCP 30(b)(6) and indicate whether he or she has personal knowledge regarding the subject loan transaction prior the deposition date.

2. In Exhibit 2, New Century Mortgage denied the mortgage application on March 9, 2004. Please provide the name of the person who made that decision and have him or her present at the deposition. If that person is not available, please state why? Otherwise, please provide a ‘designated deponent’ [Name] & [address] that is likely to have discoverable information relevant to Consumer Creditor’s claims as per FRCP 30(b)(6) and indicate whether he or she has personal knowledge regarding the subject loan transaction prior the deposition date.

3. In Exhibit 3, Commonwealth Land Title Insurance Company (Non-Party) reported on March 29, 2004 that the title was clear for closing. Please provide the name of the person who made that decision and have him or her present at the deposition. If that person is not available, please state why? Otherwise, please provide a ‘designated deponent’ [Name] & [address] that is likely to have discoverable information relevant to Consumer Creditor’s claims as per FRCP 30(b)(6) and indicate whether he or she has personal knowledge regarding the subject loan transaction prior the deposition date.

4. In Exhibit 4, Consumer Creditor and a Party In Interest was issued a mortgage. Please provide the name of the person who made that decision and have him or her present at the deposition. If that person is not available, please state why? Otherwise, please provide a ‘designated deponent’ [Name] & [address] that is likely to have discoverable information relevant to Consumer Creditor’s claims as per FRCP 30(b)(6) and indicate whether he or she has personal knowledge regarding the subject loan transaction prior the deposition date.

In accordance to FRCP 26(a)(1)(A), you must voluntarily disclose additional names, addresses and telephone numbers of each individual & non-parties likely to have discoverable information. The disclosure must also clearly indicate “The subjects of the information” of each these individuals knows, their title, company affiliation, copy of their job description and to whom they report at their respective companies.

4. FULL DISCOVERIES RIGHTS GRANTED By Judge Kevin J. Carey on August 20, 2008, Extracted from August 20, 2008 Transcript, page 69

“MR. AUGUSTIAN: -- you gave the option to -- to the attorney Christopher whether I should proceed as an adversary proceeding or contested matter. He chose adver -- contested matter. I was not called forward to ask my opinion. That’s why I stepped forward to --

THE COURT: Yeah. Well, the --

MR. AUGUSTIAN: -- let the Court know.

THE COURT: I guess the -- the short way of -- of responding to that is we can design pre -- pretrial procedures basically to afford whatever due process rights you would like to have. So, in substance, there’s going to be no difference at the end of the day. So, you will have all the rights that you would have had had this been commenced as an adversary proceeding. And, it’s actually procedurally probably better for you that it proceed that way. So, we’ll make it so that there is no difference. Do you understand what I’m saying?

MR. AUGUSTIAN: Yes, Your Honor. I was just reading the -- the rules as it states. So, I am not expert in the law. But, if you feel that way, that I -- all my rights will be protected, then -- it’s on the record.

Then, if -- if some time I feel it does not and something fall through the crack, I’ll file an appeal.

5. NON-PARTIES ORDINARY WITNESSES
Please review the certificate of service for the complete lists of non-parties ordinary witnesses and their attorneys in the above matter. Non Parties Witnesses (someone and companies) are not a party in this matter but the records they hold have some bearing on his claims and New Century Mortgage Corporation had transactions with the non-parties in relation to Consumer Creditor’s mortgage and business loan.

Rule 34 of the Federal Rules of Civil Procedure, which provides that “any party may serve on any other party a request to produce and permit the party making the request, or someone acting on the requestor’s behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phono records, and other data compilations from which information can be obtained, translated, if necessary, by the respondent through detection devices into reasonably usable form) ...” [Emphasis supplied]. Rule 1001(1) of the Federal Rules of Evidence provides: “Writings” and “recordings” consist of letters, words or numbers or their equivalent, set down by handwriting, typewriting, printing, photostating, photographing, magnetic impulse, mechanical or electronic recording or other form of data compilation [Emphasis supplied]. Therefore, Non-Parties Witnesses are prime ordinary witness subject to discovery and deposition in accordance with the rule of law.

6. NOTICE TO REQUEST ‘RAW FACTS & REAL EVIDENCE’ from All Counsels of Non-Parties & Non-Parties Witnesses
Now the time has come, in view of the financial crisis, for the opposing Counsels to move behind the legal technicalities and abide by their oath for due diligences…

“I (repeat the name) solemnly swear that I will do no falsehood, nor consent to the doing of any in court; I will not wittingly or willingly promote or sue any false, groundless, or unlawful suit, or give aid or consent to the same; I will delay no man for lucre or malice; but I will conduct myself in the office of an attorney within the courts according to the best of my knowledge and discretion, and with all good fidelity as well to the courts as my clients. So help me God”

… because the $700 billion bailout to Financial Institutions on Wall Street by our Political Leaders and Public Officials resulted out from poor mortgage underwriting practices encouraged by the banks involved in this matter.

Reflectively, Consumer Creditor stands before the opposing Counsels with a sense of sadness for the ongoing foreclosure crisis has resulted in the largest currency devaluation in modern U.S. History and affects every American and every foreign person, government, agency, village or city that put money into pooled funds of the collateralized debt obligations CDO’s.” Let us all hope and pray that the bailout stabilized local, national and global financial market and economical activities.

The timing of these economical, financial and operative facts mentioned above are intertwined with Consumer Creditor’s matter and are always considered fair game for discoveries. So too are the legal theories and defenses of the action along with all real evidence that any party has obtain or discover (Myers v. City of Highland Village, 212 F.R.D. 324 (E.D. Tex. 2003). The scope of permissible discovery under the Federal Rules of Civil Procedure as with all of its state counterparts is very broad. Rule 26(b)(1) specifically permits discovery of “any matter, not privileged, which is relevant” with respect to any “claim” or “defense.”

The subsection then takes the trouble to list certain examples, such as “books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter.” If there is any point or purpose at all to the discovery process, it must enable Consumer Creditor’s access to those raw facts and pieces of “hard evidence” that form the underlying basis for the subject matter. These are the one-of-a-kind materials and information that the court have always make available through discovery.

(Extract from the August 20, 2008 Transcript p 70: 12-21, “Obviously you had said why don’t you, in the meantime, reach out to Mr. Augustian, investigate the facts and circumstances on -- you know, from a substantive perspective, and determine whether or not there’s any way to settle the claim. I did commence an investigation and spoke with the former general counsel of the company, who is now functioning as a consultant. The results of that investigation at our transition meeting I did produce to Mr. Carickhoff, so he has them)

Experts who are to testify and who also provide analysis, guidance, reports and opinions are witnesses nonetheless. An expert may wear the hat of a “consultant,” but his status as a testifying witness trumps the consultant status. In particular, as a testifying expert, he is certainly subject to discovery. Rule 26(a)(2)(B) mandates both the preparation and disclosure of a written signed report. According to that rule, the report:

“... shall contain a complete statement of all opinions to be expressed and the basis and reasons therefore; the data or other information considered by the witness in forming the opinions; any exhibits to be used as a summary of or support for the opinions; the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten years; the compensation to be paid for the study and testimony; and a listing of any other cases in which the witness has testified as an expert at trial or by deposition within the preceding four years.”

The Counsels should not use the Work Product Doctrine as a device for hiding facts or evidence that are discoverable. Those hoping to erect a shield for such information often mix the hard evidence with work product materials, or try to mis-characterize such evidence as work product United States v. Dentsply Int’l, 187 F.R.D. 152 (D.Del. 1999); United States v. Frederick, 182 F.3d 496 (7th Cir. Wis. 1999); Starlight Int’l, Inc. v. Herlihy, 186 F.R.D. 626 (D.Kan. 1999). Common sense dictates that all parties should be entitled to know the underlying predicates and defenses of all of the other parties.

CONCLUSION
The Advisory Committee Notes for the 2006 amendments to Rule 34(b) state as follows: Rule 34(b) provides that a party must produce documents as they are kept in the usual course of business or must organize and label them to correspond with the categories in the discovery request. The production of electronically stored information should be subject to comparable requirements to protect against deliberate or inadvertent production in ways that raise unnecessary obstacles for the requesting party. As provided in Rule 45, If requested documents are within the control of a party upon whom a valid request is made, that party must obtain and produce those documents (Pleasant v. Pleasant, 632 A.2d 202, 97 Md.App. 711 (1993)). If you have any questions whatsoever, my contact information is below. Thank you.

Respectfully Submitted,

Pierre R. Augustin, MPA, MBA, Pro Se, Consumer Creditor
3941 Persimmon Drive, #102, Fairfax, VA 22031 Tel: (617) 202-8069
Cc: Counsels for Non-Parties Witnesses & Non-Parties Witnesses

CERTIFICATE OF SERVICE
I hereby certify that a true copy of this letter was mailed to the parties and attorneys below.

Pierre R. Augustin, Pro Se, 3941 Persimmon Drive, #102, Fairfax, VA 22031, Tel: 617-202-8069 Cert# = Confirmation of receiving Notice to Depose

Attorneys, non-parties and parties served
Officers and Head of Legal Department
Commonwealth Land Title Ins. Co.
PO Box 908
Manchester, NH 03105 ®
CERT#: 7008 0150 0000 4562 1166
Status: Delivered
Your item was delivered at 9:04 AM on October 10, 2008 in MANCHESTER, NH 03101.

Unites States Bankruptcy Court
District of Delaware, Clerk’s Office
824 N. Market Street
Wilmington, DE 19801
CERT#: 7008 0150 0000 4562 1197
Status: Delivered
Your item was delivered at 7:03 AM on October 14, 2008 in WILMINGTON, DE 19801.

Officers and Head of Legal Department
Standard and Poor’s
55 Water Street
New York, New York 10041
CERT#:7008 1140 0001 0014 7150
Status: Delivered
Your item was delivered at 9:20 AM on September 22, 2008 in NEW YORK, NY 10274. Officers and Head of Legal Department

Allied Home Mortgage Capital Corp.
401 Edgewater Place
Wakefield, MA ® Officers®
CERT#: 7008 0150 0000 4562 1173

Officers and Head of Legal Department
Real Time Solutions, Inc.
1750 Regal Row, Suite 120
Dallas, TX 75235
CERT#:7008 1140 0001 0014 7167
Status: Delivered
Your item was delivered at 9:38 AM on September 22, 2008 in DALLAS, TX 75235.

Officers and Head of Legal Department
Danversbank
One Conant Street
Danvers, MA 01923
978-777-2200
CERT#:7008 1140 0001 0014 7013
Status: Delivered
Your item was delivered at 8:32 AM on September 22, 2008 in DANVERS, MA 01923.

Officers and Head of Legal Department
Deutsche Bank National Trust Company OR Chase Home Finance
10790 Rancho Bemado Rd
San Diego, CA 92127
800-548-7912 ®
CERT#: 7008 0150 0000 4562 1180
Status: Delivered
Your item was delivered at 10:58 AM on October 7, 2008 in SAN DIEGO, CA 92127.

Officers and Head of Legal Department
Deutsche Bank Securities
U.S. Headquarters
60 Wall Street
New York, NY 10005
CERT#:7008 1140 0001 0014 7020
Status: Delivered
Your item was delivered at 12:03 PM on September 22, 2008 in NEW YORK, NY 10268.

Officers and Head of Legal Department
KPMG LLP (“KPMG”)
345 Park Ave
New York, NY 10022
CERT#:7008 1140 0001 0014 7051
Status: Delivered
Your item was delivered at 2:05 PM on September 22, 2008 in NEW YORK, NY 10154.

Officers and Head of Legal Department
Ameriquest Mortgage Company
1100 Town & Country Road
Orange, CA 92868
CERT#:7008 1140 0001 0014 7037
Status: Delivered
Your item was delivered at 12:55 PM on September 19, 2008 in ORANGE, CA 92868.

Officers and Head of Legal Department
Old Republic National Insurance
400 Second Avenue South
Minneapolis, MN 55401-2499
(800) 328-4441
CERT#:7008 1140 0001 0014 7181
Status: Delivered
Your item was delivered at 9:06 AM on September 22, 2008 in MINNEAPOLIS, MN 55401.

Officers and Head of Legal Department
Beacon Appraisal
396 W. Broadway
Boston, MA 02127
617-269-1210
CERT#: 7008 1140 0001 0014 7044
Status: Delivered
Your item was delivered at 11:55 AM on September 20, 2008 in BOSTON, MA 02127.
Legal Department
Small Business Administration (SBA)
SBA Loan#: LDP5329494000
SBA Loan Name: Admerk Corp. Inc.
Note date: May 17, 2002

Officers and Head of Legal Department
Chase Home Finance
4915 Independence Parkway, 2nd FL, Legal Dept.
Tampa, FL 33634 ®
CERT#:7008 1140 0001 0014 7174
Status: Delivered
Your item was delivered at 10:38 AM on September 19, 2008 in SAN DIEGO, CA 92128.

Counsel to the Debtors
Suzzanne S. Uhland, Ana Acevedo, Emily R. Culler
O’Melveny & Myers LLP
275 Battery Street
San Francisco, CA 94111
T: (415) 984-8700, F: (415) 984-8701

Co-Counsel to the Debtors
Mark D. Collins, Michael J. Merchant, Christopher M. Samis
Richards, Layton & Finger, P.A.
One Rodney Square, P.O. Box 551
Wilmington, DE 19899
T: (302) 651-7700

Real Time Solution, Inc.
1750 Regal Row, Ste 120
Dallas, TX 75235
Attorney, David W. Carickhoff, Jr
Blank Rome LLP
Chase Manhattan Centre
1201 Market Street, Suite 800
Wilmington, DE 19801
302-425-6400

Joseph J. McMahon, Jr., Esquire
United States Department of Justice
Office of the United States Trustee
J. Caleb Boggs Federal Building
844 King Street, Suite 2207, Lockbox 35
Wilmington, DE 19801, Courtesy copy

President
Tedd Chambler
Commonwealth Land Title Insurance Company Inc
5600 Cox Rd
Glen Allen, VA 23060-9266

United States Bankruptcy Court
District of Delaware
824 Market Street, 3rd Floor
Wilmington, DE 19801
T: (302) 252-2900

U.S. Trustee
United States Trustee
844 King Street, Room 2207
Lockbox #35
Wilmington, DE 19899-0035
302-573-6491

President
Thomas Jacob
Chase Home Finance
194 Wood Ave S # 2
Iselin, NJ 08830

Official Committee of Unsecured Creditors
Attorney, Bonnie Glantz Fatell
Blank Rome LLP
1201 Market Street, Suite 800
Wilmington, DE 19801
(302) 425-6423

Attorney, Christopher M. Samis
Richards, Layton & Finger, P.A.
920 N. King Street
Wilmington, DE 19801
302-651-7845

Deutsche Bank National Trust
300 S. Grand Ave, Ste 3950
Los Angeles, CA 90071

Chairman and CEO
Timothy P. (Tim) Flynn
KPMG LLP (“KPMG”)
757 Third Ave.
New York, NY 10017

President
Deven Sharma
Standard and Poor’s
55 Water Street
New York, New York 10041

Jonathan R. Goldsmith
Jonathan R. Goldsmith, Esq
1350 Main Street
10th Floor
Springfield, MA 01103
413-747-0700
trusteedocs1@jgoldsmithlaw.com
Assigned: 12/16/2005

Jonathan R. Goldsmith
Jonathan R. Goldsmith, Esq
1350 Main Street
10th Floor
Springfield, MA 01103
413-747-0700
trusteedocs1@jgoldsmithlaw.com
1. Cert#:70073020000233248181
Status: Delivered
Your item was delivered at 3:05 PM on September 22, 2008 in SPRINGFIELD, MA 01103.

Giles Krill
Law Offices of Edward A Gottlieb
309 Washington St
Brighton, MA 02135
617-789-5678
Assigned: 03/23/2006 Commonwealth Land Title Ins. Co.
1. Cert#:70073020000233249174
Status: Delivered
Your item was delivered at 11:37 AM on September 18, 2008 in BRIGHTON, MA 02135.

Charles A. Lovell
Partridge,Snow & Hahn LLP
180 South Main Street,
Providence, RI 02903-7120
(401) 861-8200
cal@psh.com
Assigned: 10/03/2006
representing Chase Home Finance LLC
1. Cert#: 70073020000233249297
Status: Delivered
Your item was delivered at 8:45 AM on September 18, 2008 in PROVIDENCE, RI 02903.
Lauren A. Solar
Barron & Stadfeld, P.C.
100 Cambridge Street
Suite 1310
Boston, MA 02114
617-723-9800
las@barronstad.com
Assigned: 12/10/2005 representing Deutsche Bank National Trust Company, Trustee
1. Cert#:7007 3020 0002 3324 9280
Status: Delivered
Your item was delivered at 10:11 AM on September 18, 2008 in BOSTON, MA 02114.

Ronald S. Allen
Morgan, Brown & Joy LLP
200 State Street
11th Floor
Boston, MA 02109
617-523-6666
617-367-3125 (fax)
rallen@morganbrown.com
Assigned: 05/22/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing 1.Cert#:7007 3020 0002 3324 9273
Status: Delivered
Your item was delivered at 10:32 AM on September 18, 2008 in BOSTON, MA 02109.
Allied Home Mortgage Capital Corp.

CEO, Aseem Mital
Ameriquest Mortgage Company
1100 Town & Country Rd., Suite 1200
Orange, California 92868

R. Bruce Allensworth
Kirkpatrick & Lockhart, Nicholson Graham LLP - MA
One Lincoln Street
Boston, MA 02111-2950
617-261-3119
617-261-3175 (fax)
ballensworth@klng.com
Assigned: 10/05/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing 1. Cert#:7007 3020 0002 3324 9266
Status: Delivered
Your item was delivered at 11:41 AM on September 18, 2008 in BOSTON, MA 02205.
Ameriquest Mortgage Company

John Connolly, Jr.
Law Offices of John Connolly, Jr.
One Common Street
Wakefield, MA 01880
781-245-5490
781-246-4114 (fax)
Assigned: 06/09/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing 1. Cert#: 7007 3020 0002 3324 9259
Status: Delivered

Your item was delivered at 9:35 AM on September 18, 2008 in WAKEFIELD, MA 01880.

Old Republic National Insurance

David J. Gallagher
Regnante, Sterio & Osborne
401 Edgewater Place
Suite 630
Wakefield, MA 01880-6210
617-246-2525
781-246-0202 (fax)
dgallagher@regnante.com
Assigned: 05/26/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing 1. Cert#:7007 3020 0002 3324 9242
Status: Delivered

Your item was delivered at 2:12 PM on September 19, 2008 in WAKEFIELD, MA 01880.

DanversBank

Kevin P. Geaney
Connolly Law Offices, LLC
545 Salem Street
Wakefield, MA 01880
781-557-2000
781-246-1441 (fax)
kgeaney@wakefieldlaw.com
Assigned: 06/09/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing 1. Cert#:7007 3020 0002 3324 9235
Status: Delivered

Your item was delivered at 12:37 PM on September 18, 2008 in WAKEFIELD, MA 01880.


Old Republic National Insurance

Samuel P. Reef
Law Offices of Samuel P. Reef
144 Main Street
Brockton, MA 02301
508-559-0300
508-587-7305 (fax)
Assigned: 07/31/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing 1. Cert#: 7008 1140 0001 0014 6993
Status: Delivered

Your item was delivered at 5:12 PM on September 22, 2008 in BROCKTON, MA 02301.


Samuel P. Reef

Alan H. Segal
Law Office of Alan H. Segal
220 Forbes Road
Suite 301
Braintree, MA 02184
617-848-6272
Assigned: 11/03/2006
LEAD ATTORNEY
ATTORNEY TO BE NOTICED representing
1.Cert#:7008 1140 0001 0014 7006
Status: Delivered
Your item was delivered at 1:16 PM on September 22, 2008 in NEEDHAM HEIGHTS, MA 02494. Alen H. Segal
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