IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

OF FLORIDA, IN AND FOR BREVARD COUNTY

CHASE HOME FINANCE LLC, Case No.: 05-2009-CA-74735

Plaintiff,
v.

THOMAS A. WEBSTER, et al

Defendant, Pro Se
____________________________________________/

DEFENDANT THOMAS A. WEBSTER’S FIRST SET OF INTERROGATORIES TO

PLAINTIFF CHASE HOME FINANCE LLC

Defendant Thomas A. Webster, (“Defendant”), Pro Se, pursuant to Rule 1.340 of the
Florida Rules of Civil Procedure, hereby propounds these Interrogatories to Plaintiff, Chase
Home Finance LLC, (“Plaintiff”), to be answered in writing, under oath, and within thirty (30)
days from the date of service hereunder.

If any of the following Interrogatories cannot be answered in full after exercising due
diligence to secure the information, please so state and answer to the extent possible, specifying
your inability to answer the remainder, and state whatever information you have concerning the
unanswered portions. If your answer is qualified, state the qualifications.

INSTRUCTIONS FOR USE

A. All information is to be divulged which is in the possession of Plaintiff, its

attorneys, investigators, agents, employees or other representatives.

B. Where an individual Interrogatory calls for an answer which involves more than
one part, each part of the answer should be clearly set out so that it is understandable.

Defendants First Set Note Interrogatories

 C. A space has been provided on the form of interrogatories for your answer. In the
event this space provided is not sufficient for your answer to any of the questions, please attach a
separate sheet of paper with the additional information.

D. Each interrogatory shall be answered separately and fully in writing, unless it is

objected to, in which event, the reasons for the objections shall be stated in lieu of an answer.
The answers are to be signed by the person making them, and the objections signed by the
attorney making them.

DEFINITIONS

A. As used herein, "you" or "your" means Plaintiff, its agents, representatives and all
other persons acting on behalf of Plaintiff.

B. As used herein, the term "document" or "documents" include, but are not limited
to, the note that is the subject of this action, all paper material of any kind, whether typed,
written, printed, punched, filmed or marked in anyway; recording tape or wires, film,
photographs, movies or any graphic matter however produced or reproduced; all mechanical or
electronic sound recordings or transcripts thereof and all computer or data processing material.

C. As used herein, the term "identify" when used in reference to a document or

documents or equivalent language, means to state:

i. The identity of the person who prepared it.

ii. The identity of the person who signed it or in whose name it was issued.

iii. The identity of the person to whom it was addressed or distributed.

iv. The nature and substance of the document with sufficient particularity to
enable it to be identified.

v. Its date and if it bears no date, the date on which it was prepared.
 vi. The physical location of it and the identity of the custodian.

E. The identification should be with sufficient particularity to meet the requirements

for its inclusion in a Request for Production of Documents, pursuant to Rule 1.340 of the Florida
Rules of Civil Procedure.

F. As used herein, "affiliate", when used in relation to any person or entity, means
another person or entity who is owned or controlled (in whole or in part) by, or is under common
ownership or control (in whole or in part) with, such person or entity.

G. If you intend to claim any privilege recognized in the law against revealing any
information which is requested, or producing any document, or in revealing any document, in
addition to the foregoing information, state the applicable ones of the following: the date of and
participants to any communication; the number of pages of any document; the persons who
received such document; the relationship of such person to you; whether such document contains
facts, opinion, or both; and state the privilege you intend to claim.

INTERROGATORIES

1. Please identify the person(s) answering these interrogatories including the name,
address, telephone number, place of employment, job title and relationship to the Plaintiff.

Answer 1:
 2. Please state whether you claim to possess legal or beneficial interest, or both
interests, in the note that is the subject of this action, and if so, explain why you so claim;
identifying any document(s) and clauses therein which gives you the interest(s) you claim and
specifying whether you claim rights as an owner or holder of the note or both, and specifying any
other rights claimed. If you do not claim any such interest(s) or rights, please explain why you do
not claim such interest(s).

Answer 2:

3. Please state whether you claim to possess the authority or the power to file and
pursue foreclosure of the note that is the subject of this action, and if so, explain why you so
claim identifying any document(s) and clauses therein which gives you the authority or power
you claim. If you do not claim any such authority or power, please explain why you do not claim
such authority or power.

Answer 3:
 4. Please state the name, address and phone number of the person(s) or entity(ies)
(“assignor”) from whom you took assignment of the note that is the subject of this action,
together with the date you took assignment of the note, specifying all documents, including
contracts that were necessary to give legal effect to the assignment of the note to you. If any or
all aspects of the obtaining the note was by way of endorsement, so state.

Answer 4:

5. Please state the name, address and phone number of all persons and/or entities
(“chain of title assignors/assignees”) who obtained the note that is the subject of this action by
way of assignment, prior to the assignor referenced in paragraph 6, taking assignment of the note
that is the subject of this action, together with the date that person(s) and/or entity(ies) took
assignment of the note, specifying all documents, including contracts, that were necessary to give
legal effect to the assignment of the note to that person(s) and/or entity(ies). If any or all aspects
of obtaining the note was by way of endorsement, so state.
Answer 5:

6. Please state the date, amount and nature of the consideration or value given in
exchange for each and every assignment of the note that is the subject of this action, including
the consideration or value not only that you gave to the assignor, but the consideration or value
all those person(s) or entity(ies) in the chain of title assignors/assignees of the note gave and
received in the assignment process of this note, and identify the person(s) and/or entity(ies)
giving and receiving such consideration or value by providing their full legal name(s), address,
and phone number and specify the consideration or value that was exchanged for the assignment
of the note.

Answer 6:
 7. Please state if the note that is the subject of this action was ever subject to, or
included in, a “mortgage loan purchase agreement” or similar agreement and if so, please
completely identify the agreement and specify the name to the agreement, the date of the
agreement and any amendments, and the parties to the agreement.

Answer 7:

8. Please state whether the note that is the subject of this action was ever
repurchased or reassigned from the buyer or assignee back to the original seller or assignor or to
any predecessor of the buyer or assignee and, if so, state the dates of such and the parties
involved.

Answer 8:
 9. Please explain and describe for the note that is the subject of this action: the
relationships among parties (including you, the original lender, any servicer, any custodian, any
depository, any special purpose vehicle or special purpose entity); the structure of the securities
offered (including the flow of funds or any subordination features); and any other material
features of any transaction concerning the sale, transfer or assignment of the note at any time
between the making of same and your filing of the action at issue herein.

Answer 9:

10. Please identify each and every document which contains an obligation or option
to repurchase the note that is the subject of this action and explain fully the terms, conditions and
costs to be incurred or paid by each party upon repurchase; and whether and by whom, and from
whom the note was ever repurchased.

Answer 10:
 11. Please state, for the note whether and as of what date you secured the original
thereof and from whom, providing the contact name, address, and phone number of each such
person.

Answer 11:

12. Please identify each and every document you obtained or reviewed in connection
with your taking assignment of the note and specify for each such document whether you
maintain the original or a copy thereof.

Answer 12:
 13. Please state all parties who have provided servicing of the note and provide the
contact name, full legal name, address, and phone number of each such party and the dates each
began servicing the note and the compensation paid and the dates paid, for such servicing of the
note.

Answer 13:

14. Please state for the history of the note, the persons or entity who, at any time,
collected note payments, specifying the sums collected, the applicable dates each person or entity
did so collect and specifying the full legal name, address, and phone number of each such person
or entity.

Answer 14:

15. Please state for the history of the note that is the subject of this action: a full
description of the disposition of collected note payments specifying any person or entity to which
note payments were delivered, transferred, or paid; the applicable dates each such person or
entity received the payments; and further specify the full legal name, address and phone number
of each such party.

Answer 15:
 16. In relation to the note that is the subject of this action, please define the minimum
legal requirements necessary to assign the subject note.

Answer 16:

17. If you intend to indemnify the plaintiff against claims by someone later claiming
to be entitled to enforce the note against the defendant, please state the basis for your being able
to make such indemnification.

Answer 17:
 18. State whether the federal government has a financial interest in this Note by way
of underwriting, guarantee, indemnification or ownership.

Answer 18:

19. State all federal pre-suit default prevention measures you undertook prior to filing
this action.

Answer 19:
 20. State whether any partial or fractional interest of this Note had at any time been
sold, as referenced in the mortgage at paragraph 20, and the name(s) and address(es) of all
parties who obtained such partial or fractional interest.

Answer 20:

21. Please identify a representative of Plaintiff with knowledge of the facts necessary
to respond to each of the interrogatories contained herein or, if more than one, identify each such
representative providing the name, address, and telephone number for each with a brief summary
of each representative’s knowledge in this matter.

Answer 21:
 By: _____________________________________

Title: ___________________________________

Print Name: _____________________________

STATE OF _______________________

COUNTY OF _____________________

The foregoing instrument was sworn and acknowledged before me by

_______________________________________who is personally known to me or

produced_____________________ as identification on this __________ day of
_________________, 2010.

__________________________________________

NOTARY PUBLIC, State of _________________

Print Name:_______________________________

My commission expires:_____________________
Respectfully Submitted,

May 6, 2010

______________________
Thomas A. Webster
Defendant, Pro Se
4655 Elena Way
Melbourne, FL 32934

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been furnished by U.S. Mail,
this 6th day of February, 2010, to Ashleigh L. Politano, Esq., Florida Default Law Group, P.L.,
9119 Corporate Lake Drive, Suite 300, Tampa, Florida 33634

______________________________
Thomas A. Webster