COURT COMMON OF PLEAS CHESTER OF COUNTY, PENNSYLVANIA _ CIVIL ACTION LAW MARY ANNSMILER Plaintiff

V.

No. 11-05832 NOTICE PRODUCE TO DOCUMENTS DIRECTED DEFENDANT TO BY PLAINTIFF

NATIONSTAR MORTGAGE, LLC Defenrdants

To:

MaryAnn Smiler Nationstar vs. Mortgage, LLC

PLEASE TAKENOTICE the Plaintiff that Mary Ann Smiler, hereby requests the that Defendant, Nationstar Mortgage, LLC,produce documents responsive the within to request within timeprovided the Rules the Court. the by of Thisrequest deemed be is to continuing andincluding timeof trial. up the

CHERI ROBINSON ASSOCIATES &

Date:August19,2011

By: Cheri Robinson, Esq,

1 . Pleaseproduce every document which is in the possessionof Defendant or reasonablyavailable to Defendant concerning the incorporatiory formation creation of MERS as a legal entity in any form or iteration. This request is specifically meant to include any predecessors interest of MERS and any in parent or subsidiary corporations or legal entities. RESPONSE: and

2. Pleaseproduce every corporate resolution where MERS authorized any person

or entity to act as a "certifying officer" of MERS with respect to this assignment of mortgage. RESPONSE:

3. Please produce every corporate resolution where the MERS Board aathorized, any person or entity to appoint anyone a "cerhfying officer" oI MERS with respeclt this assignmentof mortgage. to RESPONSE:

4. Pleaseproduce every corporate resolution, minute meetings or other documents demonstrating William Hultman's abilify to appoint anyone a "yice president,, and/ or "Assistant Secretary" of MERS. RESPONSE:

5. Please produce every document, memorandum, report, communicatioru or correspondence by any medium (electronic, print, typewritten, voicemail,

recording, etc.) where MERS discussed or considered the creation of a "Cert'dying Officer" label, name or position for MERS. RESPONSE:

6- Please produce a copy of any executed agreements between MERS and the defendant to this action. RESPONSE:

7. Please produce a copy of all of the entities that have been known as MERS,s bylaws, charter, authority to operate and incorporation documents. RESPONSE:

8. Pleaseproduce a copy of all corporate resolutions that have been adopted by the current MERS that were originated andf or ratified by a previous entity known as MEITS RESPONSE:

9. Please produce all of the member information stored in the MERS system for every entity identified in the responsesto this written discovery which has an ORG ID on the MERS system. RESPONSE:

L0' Pleasestate the name and identity of every agreement that exists between MERS and any other defendant to this action including any applicable insurance, reinstrance or indemnity agreements.

a. For each such agreement so identified please describe the agreement with sufficient particularity to delineate between each agreementso identified. b. Pleaseproduce a copy of every such agreement so identified. RESPONSE:

11". Pleaseproduce a copy of every Power of Attorney for any person signing any of the documents requestedin any of theseinterrogatories RESPONSE:

12. Pleaseproduce a copy of all documents that purport to grant authorify to any person to sign any of the documents referencedin this discovery. RESPONSE:

13. Pleaseproduce a complete copy of your Rules of Membership. RESPONSE:

14. Pleaseidentify every rule of membership which has been altered in the last ten years and produce any previous versions of any rules which have been altered, amended or modified in the last ten years. RESPONSE:

15' Pleaseproduce the notary registration book for any notary public who certified the signafure of any person on any document produced in this discovery. RESPONSE:

16' Pleaseproduce the MIN transfer audit for the subject loan in this case. RESPONSE:

1"7. Pleaseproduce the MIN audit for the subiectloan in this case. RESPONSE:

L8' Pleaseprovide a complete copy of the MERS membership agreement executed by any signer of and/ or witness to this assignment of mortgage. RESPONSE: