SUPERIOR COURT OF NEW JERSEY

CANCERY DIVISION – ESSEX VICINAGE

------------------------------------------------------------------X Civ
il Action
Deutsche Bank National Trust Company# as Trustee of
Argent Securities, Inc. Asset Backed Pass Through
Certificates, Series 2004-PW1
Docket Number: XXX

REQUEST FOR
Plaintiff(s),
PRODUCTION OF
DOCUMENTS
vs.

XXX; JOHN DOE,

HUSBAND OF XXX,
XXX Ave
Rosedale, NY 11422
Defendant(s) Pro-Se
------------------------------------------------------------------X
REQUEST FOR DISCOVERY: PRODUCTION OF DOCUMENTS
XXX serves this Request for Production of Documents on Deutsche Bank N
ational Trust Company, per Case Management Order dated September 30, 2009, and a
s authorized by Federal Rule of Civil Procedure 34. As required by this Order an
d Rule 34(b), Deutsche Bank National Trust Company must produce all requested do
cuments for inspection and copying either as they are kept in the ordinary cours
e of business or segregated according to each request. The documents must be pro
duced within 30 days of service of this request at: XXX, XXX Ave, Rosedale, NY 1
1422.
INSTRUCTIONS
i). These requests for production of documents are directed toward all informati
on known or available to Deutsche Bank National Trust Company - not its lawyers
with no firsthand knowledge of the records in this instant case - including info
rmation contained in the records and documents in Deutsche Bank National Trust C
ompany’s custody, control or available to Deutsche Bank National Trust Company u
pon reasonable inquiry. Where requests for documents cannot be answered in full,
they shall be answered as completely as possible. No answer or an incomplete an
swer shall be accompanied by a specification of the reasons for the lack of answ
er and the incompleteness of the answer and of whatever actual knowledge is poss
essed with respect to each unanswered or incompletely answered Request for Docum
ents. Please state the name(s) of the senior officer(s) having firsthand knowled
ge of the facts herein and their title answering this request.
ii). Each Request for Documents is to be deemed a continuing one. If, after serv
ing an answer to any Request for Documents, you obtain or become aware of any fu
rther information pertaining to that Request for Documents, you are requested to
serve a supplemental answer setting forth such information.
iii). As to every Request for Documents which you fail to answer in whole or in
part, the subject matter of that document request will be deemed confessed and s
tipulated as fact to the Court.
iv). For each document or other requested information that Deutsche Bank Nationa
l Trust Company asserts is privileged or is not discoverable, identify that docu
ment or other requested information. State the specific grounds for the claim of
privilege or other grounds for exclusion.

v). For each document that Deutsche Bank National Bank Trust Company claims is
not discoverable, state (1) the information required by the definition of “docum
ent” below, (2) the author’s job title and address, (3) the recipient’s job titl
e and address, (4) the name and job title of all persons to whom it was circulat
ed or who saw it, (5) the name, job title, and address of the person now in poss
ession of the document, and (6) the document’s present location.
vi). For a document that no longer exists or cannot be located, identify the d
ocument, state how and when it passed out of existence or when it could no longe
r be located, and state the reasons for the disappearance. Also, identify each p
erson having knowledge about the disposition or loss of the document, and identi
fy any other document evidencing the lost document’s existence or any facts abou
t the lost document.
vii). As to every Request for production which you fail to answer in whole or i
n part, the subject matter of that production will be deemed confessed and stipu
lated as fact to the Court.
viii). Answer each request for production separately by listing the documents an
d by describing them as defined below. If documents are numbered for production,
in each response, provide both the information that identifies the document and
the document’s number.
DEFINITIONS
The following terms have the following meanings, unless the context requires oth
erwise:
ix). Parties. The term “plaintiff” or “defendant,” as well as a party’s full o
r abbreviated name or a pronoun referring to a party, means the party and, where
applicable, {his/her/its} agents, representatives, officers, directors, employe
es, partners, corporate parent, subsidiaries, or affiliates. This definition is
not intended to impose a discovery obligation on any person who is not a party
to the litigation.
x). Person. The term “person” means any natural person, any business, a legal
or governmental entity, or an association.
xi). Document. The term “document” is synonymous in meaning and equal in scope
to the usage of this term in Federal Rule of Civil Procedure 34(a) and includes
computer records in any format. A draft or non-identical copy is a separate doc
ument within the meaning of this term. The term “document” also includes “any t
angible things” as that term is used in Rule 34(a).
xii). Communication. The term “communication” means the transmittal of informa
tion in the form of facts, ideas, inquiries, or otherwise.
xiii). Identify (person). When referring to a person, “identify” means to give
to the extent known the person’s full name, present or last known address, tele
phone number, and, when referring to a natural person, the present or last known
place of employment. Once a person has been identified in compliance with this
paragraph, only the name of that person needs to be listed in response to later
discovery requesting the identification of that person.
xiv). Identify (document). When referring to a document, “identify” means to g
ive, to the extent known, the following information: (1) the type of document; (
2) the general subject matter of the document; (3) the date of the document; (4)
the authors, addressees, and recipients of the document; (5) the location of th
e document; (6) the identity of the person or entity who has custody of the docu
ment; and (7) whether the document has been destroyed, and, if so, the (a) date
of its destruction, (b) reason for its destruction, and (c) identity of the pers
on who destroyed it.
xv). Relating. The term “relating” means concerning, referring, describing, ev
idencing, or constituting, directly or indirectly.
xvi). Any. The term “any” should be understood in either its most or its least
inclusive sense as necessary to bring within the scope of the discovery request
all responses that might otherwise be construed to be outside of its scope.
xvii). And/Or. The connectives “and” and “or” should be construed either disju
nctively or conjunctively as necessary to bring within the scope of the discover
y request all responses that might otherwise be construed to be outside of its s
cope.
xviii). Number. The use of the singular form of any word includes the plural a
nd vice versa.
xiv). Deutsche Bank National Trust Company includes any and all persons, all p
ast and current employees and agents acting, for in concert or behalf of Deutsch
e Bank National Trust Company each of your directors, employees, fiduciaries, re
presentatives and agents, of this allege plaintiff, and any individual over whic
h this allege plaintiff, exercises the power to control and direct as well as ev
eryone acting for or on behalf of Deutsche Bank National Trust Company having fi
rsthand knowledge.
xx). “Documents” or “documents” means writings of every kind and character pert
aining to the designated subject matter, including, without limitation and not l
imited to, the original and a certified copy, regardless of origin or location,
of any regulation, court decision, book, pamphlet, periodical, letter, memorandu
m, file, note, diary, calendar, newspaper, magazine, statement, bill, invoice, o
rder, policy, telegram, correspondence, summary, receipt, opinion, investigation
statement or report, schedule, manual, financial statement, audit, tax return,
articles of incorporation, bylaws, stock book, minute book, agreement, contract,
deed, security agreement, mortgage, deed of trust, title or other insurance pol
icy, report record, study, Note which indicates or constitutes evidence of debt,
monetary instrument, contract for services or transfer of money between Plainti
ff and any other person (natural or artificial), hand written note, map, drawing
, working paper, chart, paper, draft, index, tape microfilm, e-mail, data sheet,
data processing card, computer printout, computer program, check, bank statemen
t, passbook or other written, typed, printed, photocopied, dittoed, mimeographed
, recorded, transcribed, punched, taped, filmed, photographic or graphic matter,
however produced, to which you have or have not had access.
xxi). The term “equity in the original note” refers to the fact that not only d
oes Deutsche Bank National Trust Company have physical possession of the origina
l promissory note and custody like a fiduciary, but must have also vested financ
ial interest in such: it legally belongs to Deutsche Bank National Trust Company
.
DOCUMENTS REQUESTED
1) Please identify the true owner of this obligation pursuant to 15 U.S.C.
§ 1641(f)(2) and describe your relationship to this entity.
RESPONSE:

2) Produce copies of complaints or petitions in any action filed by or agai

nst Deutsche Bank National Trust Company in which allegations are similar to tho
se of this suit.
RESPONSE:
3) Produce settlement agreements that Deutsche Bank National Trust Company
has entered into with any party or non-party as a result of or relating to this
instant case.
RESPONSE:

4) For each payment received, produce a complete payment history, including

but not limited to the dates and amounts of all the payments that have been mad
e on the alleged loan to date, how the payment was applied or credited (indicati
ng the portion, if any, applied or credited to principal, interest, escrow or su
spense, and any Servicer), the month to which the payment was applied and if int
erest and principle is calculated using an daily actuarial accounting method;
RESPONSE:

5) Produce a certified copy of all Truth in Lending material disclosures pr

ovided at any purported closing and all written notices that informed Defendant
of all effective dates concerning the transfer of the Note and Security Instrume
nt pursuant to 12 USC § 2605(c);
RESPONSE:

6) Produce a certified copy of all letters, statements, documents, and mate

rial disclosures sent to Defendant by Servicers, Sub-Servicers or others in your
file or in your control or possession or in the control or possession of any af
filiate, parent company, agent, Sub-Servicers, Servicers, attorney or other repr
esentative of your company;
RESPONSE:

7) Produce all accounting ledger cards, journal entries and/or bookkeeping

entries regarding the crediting of any and all Promissory Notes, money equivalen
ts, or similar instruments, identified as or evidencing assets provided by and/o
r signed by the borrowers and consumers relating to this Account.
RESPONSE:

8) Produce a copy of all account receivables or payable, (including the amo

unt, payment date, purpose, length of insurance term, and recipient of all expen
ses including appraisal fees, property inspection/preservation fees, force-place
d insurance charges, title insurance, hazard insurance, legal fees, recoverable
corporate advances) relating to this Account that Argent Mortgage Company, LLC,
Argent Securities, Inc., Deutsche Bank National Trust Company and any other bank
, depository or financial institution and/or mortgage servicers recorded in its
accounting ledger card and bookkeeping journal entries since the origination of
this loan;
RESPONSE:

9) Produce the particulars of this Account setting forth each item recorded
on the account since origination to include any and all Promissory Notes, money
equivalents, or similar instruments, identified as or evidencing assets provide
d by and/or signed by the borrower and consumers on which Deutsche Bank National
Trust Company or any other entity based an amount alleged due and owing, and th
e date that each item was delivered to the Plaintiff;
RESPONSE:
10) Produce an identification of the source of the funds used to fund the lo
an since its origination, including account name(s), number(s), and amount(s), i
ncluding identification of the source of the funds Deutsche Bank National Trust
Company used to purchase any and all Promissory Notes, money equivalents, or sim
ilar instruments, identified as or evidencing assets provided by and/or signed b
y the borrowers and consumers, and claims shall be due and owing, and the date t
he purchase was completed by Deutsche Bank National Trust Company or any subsequ
ent Servicer;
RESPONSE:

11) Produce certified copies, front and back, of all checks or wire transfer
confirmation obtained or issued by Argent Mortgage Company, LLC and used to fun
d and purchase this obligation, including all copies of checks or wire transfers
paid as third-party fees at the closing by Argent Mortgage, LLC;
RESPONSE:

Further, you are hereby requested to produce the following documents and informa
tion as related to public disclosure of securities under SEC rules and servicing
of this obligation – SEC File No.: 333-112237-01:
12) A certified copy of all recourse agreements (including, the Master Pool
ing and Servicing Agreements, the Mortgage Loan Purchase Agreement, the Trust Ag
reement, Servicer Agreement, Assignment and Assumption Agreement, SEC Forms 424(
b)(5), 8K, 10K, 10D, REMIC, NIMS Insurer) between the Servicers, Argent Securiti
es, Inc., Argent Mortgage Company, LLC, Ameriquest Mortgage Company, Deutsche Ba
nk National Trust Company and the SPV, and any other entity who claims ownership
in this obligation whereby the original promissory note agreement and collatera
l instruments were pooled and securitized into a mortgage-backed security in the
structured finance transaction;
RESPONSE:

13) Pursuant 17 CFR 240.12g5-1 provide the name of the “record holders” and/
or the name of “each person who is identified as the owner of such securities on
records of security holders maintained by or on behalf of the issuer.”
RESPONSE:

14) A certified copy of the Registration Statement as that term is defined u

nder 15 USC § 77b(a)(8), i.e.; Form 8-A (short form) and Form 10 (long form) Reg
istration Statements under the 1934 Act, Form S-1 and S-3 Registration Statement
under the 1933 Act;
RESPONSE:

15) Any request for exemption or No-action letters from SEC with respect to
their securities and all ACTS and certified copies of the application filed with
the SEC for exempt status and the order issued by the SEC granting exempt relie
f from the appropriate provisions;
RESPONSE:

16) If no registration statement pursuant to the 1933 Act is available or ot

herwise required, please provide a comprehensive description that meets the “Gen
eral Statement” of Regulation S and satisfies the conditions applied to the “Saf
e Harbor” rule.
RESPONSE:
17) The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) Pub. L. 9
7-248, 96 Stat. 324, a bearer debt security generally must be issued under arran
gements reasonably designed to ensure that such obligation will be sold only to
a person who is not a United States person and must satisfy certain other condit
ions identified in the Tax Code § 163(f)(2)(B), and as such please provide:
a) The Identify of all parties with ownership interest who have met the cri
teria as adopted by Treasury Regulation § 1.163-5(c)(i)(D) “TEFRA D” and § 1.163
-5(c)(i)(C) “TEFRA C”
RESPONSE:

b) Certified copies of all statements on a U.S. Form W-8 or substitute ther

eto certifying the owner’s non-U.S. status where the obligations issued in regis
tered form are not subject to the TEFRA rules and considered “portfolio interest
.”
RESPONSE:

c) All information statements and returns filed with the IRS which identifi
es the name and address of all recipients of interest and original issue discoun
t that meets the provisions of a U.S. obligor making payments to a foreign perso
n under the Tax Code §§ 871(a)(1), 881(a), 1441(a), 1442(a) and § 6049
RESPONSE:

18) A description whether the Special Purpose Vehicle or the originator is t

he “issuer” as that term is defined under 15 USC § 80a-2(a)(22) for registration
purposes under the Investment Company Act of 1940;
RESPONSE:

19) A description whether the pool or securities issued were required to reg
ister under the statutory or statistical definition of the 1940 Act? i.e., purs
uant 17 CFR 270.3a-7 and if exempt, describe the characteristics that define the
exception and avoids all requirements;
RESPONSE:

20) The allonge, front and back, affixed to my original promissory note with
indorsements (including the dates endorsed) relating to and/or associated with
this transaction, as outlined in the SEC Prospectus [Rule 424(b)(5)], Account No
.: 0000882377-04-001138 filed on June 1, 2004 as follows: Argent Mortgage Compan
y, LLC (Originator) sold the mortgage loan to Ameriquest Mortgage Company (Selle
r & Master Servicer) who then sold the mortgage loan to Argent Securities, Inc.
(Depositor).
RESPONSE:

Please be aware that the information contained in or filed with a Registration S

tatement as that term is defined under 15 USC § 77b(a)(8) shall be made availabl
e to the public under 15 U.S.C. § 77f(d) including any amendment thereto and any
report, document, or memorandum filed as part of such statement or incorporated
therein by reference.
Nothing in the above requested documentation is proprietary under SEC rules, and
is needed to determine accurate assignee liability and any pecuniary interest o
f Servicers and/or Trustees. Failure to provide the requested information confi
rms willful deceit on the part of Deutsche Bank National Trust Company, has lega
l implications and application under 17 CFR § 240.10b-5; (Rule 10b-5), of the 19
34 Act, and applies to everyone, including any reference to Internal Revenue Cod
e for evasion or money-laundering.

Prepared and Submitted by: XXX

XXX Avenue
Rosedale, NY
11422

CERTIFICATE OF SERVICE
I, XXX certify that on this 29th day of the month of October, 2009.
1. A true copy of the 12-page Request for Production Of Documents was served on
The New Superior Court of New Jersey, Chancery Division – Essex Vincinage, at 21
2 Wasington Street, Eighth Floor, Newark, New Jersey.
2. A copy of the foregoing was mailed on October 28 2009 to Ralph F. Casale, Esq
., 290 Route 46 West, Denville, New Jersey 07834 by Express Mail No. XXX.

Dated: Queens New York

This _________ day of ___________ 2009 XXX
XXX Ave
Rosedale, NY 11422