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CITIMORTGAGE, INC., )
)
Plaintiff, ) CASE NO.:2010-CA-008798
vs. )
)
MICHAEL J. MILLER, )
)
Defendant(s). )
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DEFENDANT’S REQUEST TO PRODUCE
______________________________________________________________________
COMES NOW the Defendants, MICHAEL J. MILLER, by and through the undersigned
counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, and request Plaintiff to
produce within thirty (30) days of the date of this Request the following documents to the
undersigned law firm of James Dalton, 800 Main St., Logwood, FL 32801, the following:
1. Subject to the foregoing conditions, produce the original promissory note signed by
2. Produce a copy of the allonge attached to the promissory note obligating Defendant
3. Produce the account and general ledger statement of each and every contract
4. Produce all bills of sale, and allonges and agreements illustrating where the promissory
note alienable in this instant case was sold or assigned for value. If none, state “none.”
6. Produce all contracts, agreements, and/or memos illustrating that Mary Smith, Esq. or
For all requests: These requests exclude documents that are considered attorney/ client
privilege or attorney work product provided Plaintiff files a list of such documents that are not
produced under protection of attorney/client privilege or attorney work product indicating the
date of the document and the title of each such document or some other means by which to
identify the document which does not disclose any protected or confidential information.
Respectfully Submitted,
____________________________
James Dalton, Esq
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been mailed to
Mary Smith Esq., Morris, Hardwick, Schneider, LLC, 5110 Eisenhower Blvd., Suite 120,
Tampa, FL 33634 on this 14th day of May 2010.