(15-00293 241-6) Ex F - Plaintiffs' Responses To Defendants' First Request For Pro

Case 1:15-cv-00293-LTS-RWL Document 241-6 Filed 10/09/17 Page 1 of 22
E[KLELW)
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
-------------------------------- x
S & A CAPITAL PARTNERS, INC., et al., :
:
Plaintiffs, : No. 15-cv-00293-LTS-JCF
:
- against - :
:
JPMORGAN CHASE BANK, N.A., et al., :
:
Defendants. :
-------------------------------- x
PLAINTIFFS’ OBJECTIONS AND RESPONSES TO DEFENDANTS’

FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
Pursuant to Federal Rules of Civil Procedure 26 and 34, Plaintiffs S&A Capital Partners,
Inc. (“S&A”), Mortgage Resolution Servicing, LLC (“MRS”) and 1st Fidelity Loan Servicing,
LLC (“1st Fidelity”) hereby submit their Objections and Responses to Defendants JPMorgan Chase
Bank, N.A., JPMorgan Chase & Co., and Chase Home Finance LLC (collectively, “Defendants”
or “Chase”) First Request for Production of Documents (the “Requests”).
GENERAL OBJECTIONS
Plaintiffs respond to the Requests set forth below subject to the following General
Objections:
1. Plaintiffs object to the Requests, including the Definitions and Instructions, to the
extent that they seek the production of documents or information that exceeds the scope of that set
forth in the Federal Rules of Civil Procedure, Local Civil Rules, and Individual Rules and Practices
of Judge Swain and/or Magistrate Judge Francis.
2. Plaintiffs object to the Requests to the extent that they seek information that may
be protected from disclosure by the attorney-client or other privileges, or the work product
doctrine.
{00018131 1 }
3. Plaintiffs object to the Requests to the extent that they seek opinion that is the
proper subject of expert testimony. Such material, if otherwise discoverable, will be provided at
the appropriate time in the appropriate context.
4. Plaintiffs object to the Requests to the extent that they seek information and
material regarding experts that is beyond the scope permitted by the Federal Rules of Civil
Procedure, Local Civil Rules, and Individual Rules and Practices of Judge Swain and/or Magistrate
Judge Francis.
5. Plaintiffs object to the Requests to the extent that they are duplicative.
6. Plaintiffs object to the Requests to the extent that they are ambiguous, vague,
overbroad, unduly burdensome, oppressive, designed to harass, or not proportional to the needs of
the case, the resources of the parties and to the extent that they do not take into account the relative
access of the parties to relevant information.
7. By responding to the Requests, Plaintiffs do not adopt the definitions given within,
or concede that the documents demanded are relevant to the subject matter of the lawsuit or the
claims and defenses, nor do they concede that the requests are proportional to the needs of the
case, the resources of the parties or take into account the relative access of the parties to relevant
information.
8. All responses submitted herein are based on the present knowledge, information
and belief of Plaintiffs and are provided subject to such information as may be recalled or produced
in the future. Plaintiffs reserve the right to revise or amend their responses as more information
becomes known.
{00018131 1 } 2
SPECIFIC OBJECTIONS AND RESPONSES
Subject to and without waiving the General Objections set forth above, and the Specific
Objections set forth within each response, Plaintiffs hereby respond to the Requests as follows:
Request No. 1
All documents that you may rely upon to support your claims or defenses in this action,
irrespective of time period.
Response to Request No. 1
Plaintiffs object to this Request on the grounds that it is overbroad, potentially subject to
the work product doctrine and impossible to ascertain at this stage of the case what documents that
Plaintiffs “may” rely upon. Subject to and without waiving the General Objections, Plaintiffs will
produce documents that are responsive to this Request.
Request No. 2
All documents referenced or described in Your Rule 26(a)(1) initial disclosures, as they
may be amended from time to time, irrespective of time period.
Subject to and without waiving the General Objections, Plaintiffs will produce documents
that are responsive to this Request.
Request No. 3
All documents upon which any allegations in the Third Amended Complaint are based,
including any documents referenced or relied upon therein, irrespective of time period.
{00018131 1 } 3
Request No. 4
A copy of the MMLSA, the MLPA, the individual note sale agreements referenced in
paragraph 15 of the Third Amended Complaint, and any other contract between You and Chase,
together with any exhibits, attachments or amendments thereto, irrespective of time period.
Request No. 5
All documents relating to any alleged conduct or misconduct on the part of Chase that falls
within the scope of the Third Amended Complaint, including but not limited to documents that
may undermine or disprove the allegations of the TAC, irrespective of time period.
Plaintiffs object to this Request on the grounds that it is overbroad and requires a
determination that is subject to the work product doctrine. Subject to and without waiving the
General Objections, Plaintiffs will produce documents that are responsive to this Request.
Request No. 6
All organizational charts covering the period from April 1, 2005 to the present for Plaintiffs
S&A Capital Partners, Inc., Mortgage Resolution Servicing, LLC, 1st Fidelity Loan Servicing,
LLC, and each of their predecessors, successors, divisions, subsidiaries, and affiliates; or (if such
organizational charts do not exist) documents sufficient to identify each of Plaintiffs’ employees,
officers and agents, including but not limited to their job titles and duties, in the period from April
1, 2005 to the present.
Plaintiffs object to this Request on the grounds that it is overbroad and unduly burdensome
both as to time period and scope and seeks information that is not relevant to the issues in this
case. Plaintiffs further object to this Request on the grounds that the information sought, to the
extent it is relevant, is more properly the subject of a narrowly tailored interrogatory. Subject to
{00018131 1 } 4
and without waiving the foregoing and the General Objections, Plaintiffs state that there are no
documents that are responsive to this Request.
Request No. 7
All documents relating to communications between You and Chase or any current or
former employees of Chase regarding this lawsuit, mortgage servicing, mortgage debt collection,
and/or the actual or potential purchase of residential mortgage loans.
Plaintiffs object to this Request on the grounds that it is overbroad, unduly burdensome
and to the extent that it seeks documents that are not related to the issues in this case. Subject to
and without waiving the General Objections, Plaintiffs will produce documents that are responsive
to this Request.
Request No. 8
All documents relating to any residential mortgage debt that You purchased from Chase,
including but not limited to purchase or bid agreements, data tapes, offers to purchase or sell loans,
promissory notes, assignments of interest, loan history documents, and any communications
regarding that debt.
Request No. 9
All documents relating to communications regarding the MMLP, the MMLSA, and any
other loan or debt sale agreements between You and Chase, including but not limited to
communications with Chase and/or with the borrowers on the loans that You acquired pursuant to
the MLPA or the MMLSA.
and to the extent that it seeks documents that are not related to the issues in this case. Plaintiffs
{00018131 1 } 5
further object to this Request to the extent that it seeks documents that may be protected from
discovery by the attorney client privilege or work product doctrine. Subject to and without waiving
the foregoing and the General Objections, Plaintiffs will produce documents that are responsive to
this Request.
Request No. 10
All documents relating to the MLPA, the MMLSA, and any other loan or debt sale
agreements between You and Chase, including but not limited to the alleged negotiation and
formation of the contracts, the alleged terms of the contracts, Chase’s alleged breaches of the
contracts, and the harm that You allegedly suffered as a result of the alleged breaches.
this Request.
Request No. 11
All documents relating to Your efforts to collect on loans acquired pursuant to the MLPA,
the MMLSA, or any other loan or debt sale agreements between You and Chase, including the
revenues, payments, and collections You received on those loans.
{00018131 1 } 6
this Request, but will not produce documents related to collection activities on loans that are not
the subject of this case.
Request No. 12
Documents sufficient to show, from April 1, 2005 to the present, the number of mortgage
loans and the amount of mortgage loan debt that You purchased from Chase, Your recovery and
realization rates on that debt, Your costs of servicing those mortgage loans, and Your revenues
and profits from servicing those mortgage loans.
Plaintiffs object to this Request on the grounds that it is overbroad both in scope and in
timeframe, unduly burdensome and to the extent that it seeks documents that are not related to the
issues in this case. Plaintiffs further object to this Request to the extent that it seeks documents
that may be protected from discovery by the attorney client privilege or work product doctrine.
Subject to and without waiving the foregoing and the General Objections, Plaintiffs will produce
documents that are responsive to this Request, but will not produce documents related to collection
activities on loans that are not the subject of this case.
Request No. 13
Documents sufficient to show, from April 1, 2005 to the present, the number of mortgage
loans and the amount of mortgage loan debt that You purchased from any source other than Chase,
Your recovery and realization rates on that debt, Your costs of servicing those mortgage loans, and
Your revenues and profits from servicing those mortgage loans.
Plaintiffs object to this Request on the grounds that it is overbroad, unduly burdensome,
designed to harass, and seeks documents that are not related to the issues in this case. Plaintiffs
discovery by the attorney client privilege or work product doctrine. Plaintiffs further object to this
{00018131 1 } 7
Request on the grounds that it seeks documents that are not proportional to the needs of the case,
or the resources of the parties. Plaintiffs will not produce documents in response to this Request.
Request No. 14
All documents relating to any civil, criminal, or administrative complaints filed against
You or to any governmental or regulatory investigations regarding Your mortgage loan servicing
business.
Plaintiffs object to this Request to the extent that it seeks documents that are not related to
Defendants’ wrongdoing, or even to the loans purchased from Defendants, or the issues in this
case. Subject to and without waiving the foregoing and General Objections, Defendants will
produce documents that are responsive to this Request and that relate to loans that are the subject
of this case.
Request No. 15
All documents relating to communications between You and any government regulators or
authorities regarding Chase, including but not limited to any communications with government
regulators related to the allegations in paragraph 145 of the TAC that Plaintiffs “face[d] the ire of
governmental entities.”
Plaintiffs note that this Request encompasses documents that are relevant to the lawsuit
now captioned United States of America et al ex rel. Lawrence Schneider v. J.P. Morgan Chase
Bank, National Association, et al., 114-CV-01047-RMC, United States District Court for the
District of Columbia and any prior caption (the “Qui Tam Case”). This Court has ordered the
parties to co-ordinate discovery in this and the Qui Tam Case. Subject to the General Objections,
Plaintiffs will produce documents that are responsive to this Request, but further note that their
production is applicable to both cases and such documents will not be re-produced in the Qui Tam
case.
{00018131 1 } 8
Request No. 16
All documents relating to Chase’s Systems of Records for mortgage loans, including but
not limited to the RCV1 System of Records referenced in paragraph 60(g) of the TAC.
Plaintiffs object to this Request on the grounds that it does not take into account the relative
access of the parties to relevant information. Such documents are in the possession, custody and
control of Defendants and are the subject of discovery in this case.
Request No. 17
All documents relating to Chase’s alleged violations of federal, state and local laws and
regulations, including alleged violations relating to the proper servicing of mortgage loans,
including but not limited to documents regarding how (if at all) Chase’s alleged conduct harmed
You.
Plaintiffs object to this Request on the grounds that it is duplicative. Plaintiffs note that
this Request encompasses documents that are relevant to the Qui Tam Case. This Court has
ordered the parties to co-ordinate discovery in this and the Qui Tam Case. Subject to the General
Objections, Plaintiffs will produce documents that are responsive to this Request, but further note
that their production is applicable to both cases and such documents will not be re-produced in the
Qui Tam Case.
Request No. 18
All documents relating to Chase’s alleged violations of any agreements with federal and
state governments, including the National Mortgage Settlement and the RMBS Settlement
referenced in paragraphs 146-47 of the TAC, including but not limited to documents regarding
how (if at all) Chase’s alleged conduct harmed You.
{00018131 1 } 9
Qui Tam Case.
Request No. 19
All documents relating to the allegations in paragraph 151 of the TAC that “(a) Chase sold
non-conforming deficiency claims in place of first lien mortgage loans; (b) Chase withheld
information and documents concerning the loans it sold to MRD; (c) Chase sold loans to MRS
where Chase had violated applicable law in its dealings with the borrowers; (d) Chase sold loans
to MRS where Chase sought [sic] MRS an uncorrupted data tape as Exhibit A to the MLPA,
substantially in the format of the November 2008 Data Tape Chase had provided to MRS; (f) Chase
accepted and retained payments it received from borrowers and/or insurance companies on loans
it had sold to MRS; and (g) Chase changed the loans sold, after the sale, by pulling valuable loans
back and adding loans that violated loan servicing and consumer protection laws.” .
Qui Tam Case.
Request No. 20
All documents relating to Your allegations in paragraphs 157 and 162 of the TAC that
Chase accepted and retained payments it received from borrowers and/or insurance companies on
loans it had sold to You.
{00018131 1 } 10
Plaintiffs object to this Request to the extent that it is duplicative of Request No. 19 or
other Requests. Subject to and without waiving the foregoing and General Objections, Plaintiffs
will produce documents that are responsive to this Request.
Request No. 21
All documents relating to Your allegations in paragraphs 61 through 64 of the TAC that
Chase misrepresented the quantity, value and principal balances of loans sold to You.
Request No. 22
Chase failed to provide You with assignments of notes and mortgages.
Request No. 23
Chase converted payments from borrowers whose loans it had sold to You.
Plaintiffs object to this Request to the extent that it is duplicative of Requests No. 19 and
20 or other Requests. Subject to and without waiving the foregoing and General Objections,
Plaintiffs will produce documents that are responsive to this Request.
{00018131 1 } 11
Request No. 24
Chase recalled valuable loans sold under the MLPA.
Request No. 25
All documents relating to Your allegations in paragraphs 78 through 83 of the TAC

regarding MRS’s efforts to mitigate its damages.
Request No. 26
All documents relating to the “post sale misconduct” referenced in paragraphs 84 through
91 of the TAC.
Request No. 27
All documents relating to allegations in the TAC regarding alleged fraud,

misrepresentation or concealment by Chase, including but not limited to the allegations included
in paragraphs 61-64, 178, 181 and 212 of the TAC.
{00018131 1 } 12
Plaintiffs object to this Request to the extent that it is duplicative of Requests No. 19 or 21
or other Requests. Subject to and without waiving the foregoing and General Objections, Plaintiffs
Request No. 28
All documents relating to the “Forgiveness Letters” referenced in paragraphs 103-31 of the
TAC, including but not limited to communications between or among You, borrowers, and Chase
regarding the “Forgiveness Letters,” Chase’s offers to buy back loans impacted by the
“Forgiveness Letters,” and Your responses to Chase’s offers.
Plaintiffs object to this Request to the extent that it does not accurately reflect the content
of the TAC. Subject to and without waiving the foregoing and General Objections, Plaintiffs will
produce documents that are responsive to this Request.
Request No. 29
For each borrower to whom You allege or have alleged that Chase improperly sent
“Forgiveness Letters,” including but not limited to Robert W. and Lauren D. Warwick, Saleh and
Beverly Ahmed, Teresa M. Hancock-Roberts, George and Theresa Lawwill, Jacob Rossatto and
Miriam Alvarez, Matthew Di Minno, Yvonne and Edward Harrity, William and Laura Spence,
Vito and Nicolette Derosa, and Marvin and Cassandra Cornish, all documents regarding that
borrower, including but not limited to Your communications with the borrower and any files that
You maintain regarding the borrower or the borrower’s mortgage loan debt.
Plaintiffs object to this Request on the grounds that the full extent of the borrowers to whom
Defendants improperly sent “Forgiveness Letters” is within the knowledge of Defendants, not
Plaintiffs, and is the subject of discovery. Plaintiffs’ response to this Request may not be construed
in any way to limit the number of recipients of the “Forgiveness Letters” improperly sent by
Defendants. Subject to and without waiving the foregoing and General Objections, Plaintiffs will
{00018131 1 } 13
produce documents that are responsive to this Request, and to the extent that it is presently aware
of the recipient’s identity.
Request No. 30
All documents relating to the alleged ‘1st Lien Alternative Foreclosure Process” and the
“Pre DOJ Lien Release Project” referenced in paragraphs 132 through 134 of the TAC.
Plaintiffs object to this Request on the grounds that the documents that are requested
primarily include documents belonging to and in the custody of Defendants, not Plaintiffs, and that
are the subject of discovery. Subject to and without waiving the foregoing and General Objections,
Plaintiffs will produce documents that are responsive to this Request.
Request No. 31
All documents relating to Chase’s alleged release of liens on properties that Chase had
previously sold to Plaintiffs, including but not limited to all documents reflecting the alleged
resulting “losses” and “damage” to Plaintiffs referenced in paragraphs 144-45 of the TAC, and all
documents regarding communications between or among You, borrowers, and Chase regarding
these lien releases.
Plaintiffs object to this Request on the grounds that the full extent of the borrowers whose
liens Defendants improperly released is within the knowledge of Defendants, not Plaintiffs, and is
the subject of discovery. Plaintiffs’ response to this Request may not be construed in any way to
limit the number of borrowers whose liens Defendants improperly released. Subject to and without
waiving the foregoing and General Objections, Plaintiffs will produce documents that are
responsive to this Request, and to the extent that it is presently aware of the borrower’s identity.
Request No. 32
For each property with respect to which You allege that Chase improperly discharged a
lien, all documents regarding the property and the borrower on the loan secured by the property,
{00018131 1 } 14
including but not limited to Your communications with the borrower and any files that You
maintain regarding the property, the borrower, or the borrower’s mortgage loan debt.
other Requests. Plaintiffs further object to this Request on the grounds that the full extent of the
borrowers whose liens Defendants improperly released is within the knowledge of Defendants, not
Plaintiffs, and is the subject of discovery. Plaintiffs’ response to this Request may not be construed
in any way to limit the number of borrowers whose liens Defendants improperly released. Subject
to and without waiving the foregoing and General Objections, Plaintiffs will produce documents
that are responsive to this Request, and to the extent that it is presently aware of the borrower’s
identity.
Request No. 33
All documents relating to the allegations in the TAC, including but not limited to paragraph
145, that Chase “destroyed the Plaintiffs’ relationships with the borrowers whose loans Plaintiffs
had purchased” and “caused substantial damage to the Plaintiffs’ business reputation,” including
but not limited to any documents reflecting or quantifying the damages allegedly caused by the
alleged harm to Plaintiffs’ business reputation.
Plaintiffs object to this Request to the extent that it is duplicative. Subject to and without
waiving the foregoing and General Objections, Plaintiffs will produce documents that are
responsive to this Request.
Request No. 34
All documents relating to the members of the RICO “enterprise” alleged in the TAC,
including the “debt collectors,” “outside services” and “persons employed by other entities who
assisted [Chase] in releasing liens” referenced in paragraph 204 of the TAC.
{00018131 1 } 15
Request No. 35
For each third party with whom Chase allegedly interfered with Your prospective
economic advantage, all documents regarding that third party, including but not limited to Your
prospective agreement with the third party, Your communications with the third party, and any
files that You maintain regarding the third party.
Plaintiffs object to this Request on the grounds that it is overly broad and unduly
burdensome and purports to seek documents that are not related to the issues in this case. Subject
to and without waiving the foregoing and General Objections, Plaintiffs will produce documents
that are responsive to this Request and are related to the issues in this case..
Request No. 36
All documents relating to any statement made by Chase that allegedly constituted a slander
of title regarding Your property, including but not limited to any documents relating to any harm
that You claim to have suffered as a result.
Request No. 37
All documents relating to any damages that You seek in this action, including but not
limited to (1) documents relating to the allegations contained in paragraphs 77-79, 153, 158, 163,
170, 175, 184, 192, 200, and 217 of the Third Amended Complaint, and (ii) [sic] documents
relating to the damages listed in the “Damages Computation” section of your Rule 26(a)(1) initial
disclosures, as they may be amended from time to time.
{00018131 1 } 16
Plaintiffs object to this Request to the extent that it is duplicative. issues in this case.
Subject to and without waiving the foregoing and General Objections, Plaintiffs will produce
documents that are responsive to this Request.
Request No. 38
All financial statements (including but not limited to statements of profit and loss) and tax
returns for S&A Capital Partners, Inc., Mortgage Resolution Servicing, LLC, 1st Fidelity Loan
Servicing, LLC, Laurence Schneider, and each of their predecessors, successors, assigns,
divisions, subsidiaries, affiliates or shareholders.
Plaintiffs object to this Request on the grounds that it is duplicative, overbroad, unduly
burdensome, designed to harass, and seeks documents that are not relevant to the issues in this
case. Further, Plaintiffs object to this Request on the grounds that it seeks confidential documents
regarding an individual who is not a party to this case. Plaintiffs further object to this Request on
the grounds that Defendants have no proper basis for demanding tax returns. Plaintiffs are
producing documents related to their damages in response to Request No. 37 and others. Plaintiffs
will not produce any additional documents in response to this Request, including but not limited
to the tax returns of any party, and will produce no documents related to the finances of Mr.
Schneider.
Request No. 39
All documents reflecting or relating to Plaintiffs’ financial performance and any alleged
diminution in the revenue, profits or value of the Plaintiff entities.
Plaintiffs object to this Request on the grounds that it is duplicative, overbroad, unduly
burdensome, designed to harass, and seeks documents that are not relevant to the issues in this
{00018131 1 } 17
case. Plaintiffs further object to this Request on the grounds that it is vague and ambiguous with
regard to the phrase “financial performance.” Plaintiffs are producing documents related to their
damages in response to Request No. 37 and others. Plaintiffs will not produce any additional
documents in response to this Request.
Request No. 40
All documents relating to (i) any form of fee or retainer agreement between You and Your
present and former legal counsel in this litigation and (ii) the billing or payment of fees, costs,
expenses or disbursements by Your present and former counsel, including but not limited to, any
timesheet records created by Your present and former counsel.
Plaintiffs object to this Request on the grounds that it is overbroad, unduly burdensome,
designed to harass, seeks documents that may be protected from disclosure by the attorney client
privilege or work product doctrine, and premature to the extent that any claim that may trigger an
award of attorney fees as an element of damages is presently the subject of a motion to dismiss.
Subject to and without waiving the foregoing and the General Objections, Plaintiffs state that in
the event that they meet the requirements to trigger an award of attorney fees, they will make the
appropriate disclosure and appropriate submissions at the appropriate time. At the present time,
Plaintiffs will not produce documents that are responsive to this Request.
Request No. 41
All documents that You receive in response to any third-party subpoenas that You issue in
connection with this litigation.
Subject to and without waiving the General Objections, and subject to any confidentiality
provisions that may be negotiated with regard to the production of documents in response to any
third-party subpoenas, Plaintiffs will produce documents that are responsive to this Request within
{00018131 1 } 18
a thirty-day timeframe of receiving such documents, subject to any condition imposed by the third-
party in question, including but not limited to the payment of costs, and to the extent that the third-
party in question has not already produced those documents to Defendants.
Request No. 42
All other documents reflecting or relating to any alleged loss, damage, injury, or breach for
which You may seek recovery from Chase.
Plaintiffs object to this Request on the grounds that it is duplicative, and to the extent that
it seeks documents that are not relevant to the issues in this case. Plaintiffs further object to this
Request to the extent that it may seek to limit recovery for any loss, damage, injury, or breach that
is not the subject of this action or that may be the subject of any related or future action, and this
Response may not be considered a waiver of such. Subject to and without waiving the foregoing
and the General Objections, Plaintiffs will produce documents that are responsive to this Request
but only with regard to the loss, damage, injury or breach that is claimed in this action.
Request No. 43
All other documents relating in any way to the allegations in the TAC.
Plaintiffs object to this Request on the grounds that it is duplicative, and with regard to the
phrase “in any way” may be overbroad, unduly burdensome, and may seek documents that are not
relevant to the issues in this case. Plaintiffs further object to this Request on the grounds that it
seeks documents that are not proportional to the needs of the case, the resources of the parties or
take into account the relative access of the parties to relevant information.
{00018131 1 } 19
Dated: New York, New York CHAITMAN LLP

January 26, 2016
By: /s/ Helen Davis Chaitman
Helen Davis Chaitman
hchaitman@chaitmanllp.com
465 Park Avenue
New York, New York 10022
Phone & Fax: 888-759-1114
Attorneys for Plaintiffs S&A Capital

Partners, Inc., Mortgage Resolution
Servicing, LLC and 1st Fidelity Loan
Servicing, LLC
{00018131 1 } 20
CERTIFICATE OF SERVICE
I, Helen Davis Chaitman, an attorney duly admitted to practice law in the State of New
York, affirm the following as true under the penalties of perjury:
That on January 26, 2016, I caused a true and correct copy of Plaintiffs’ Objections and
Responses to Defendants’ First Request for Production of Documents to be served on Defendants’
attorneys by electronic mail and by UPS as indicated below at the addresses provided by them for
that purpose:
By e-mail:
Robert D. Wick (rwick@cov.com)
Christian J. Pistilli (cpistilli@cov.com)
Michael M. Maya (Mmaya@cov.com)
Philip Levitz (PLevitz@cov.com)
Michael C. Nicholson (mcnicholson@cov.com)
By UPS:
Robert Wick
Christian J. Pistilli
Covington & Burling LLP
One CityCenter
850 Tenth Street N.W.
Washington, D.C. 20001
I declare under penalty of perjury that the foregoing is true and correct.
Dated: New York, New York /s/ Helen Davis Chaitman_____

January 26, 2016 Helen Davis Chaitman
{00018131 1 } 21

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Case 1:15-cv-00293-LTS-RWL Document 241-6 Filed 10/09/17 Page 1 of 22

UNITED STATES DISTRICT COURT

PLAINTIFFS’ OBJECTIONS AND RESPONSES TO DEFENDANTS’

or “Chase”) First Request for Production of Documents (the “Requests”).

of Judge Swain and/or Magistrate Judge Francis.

the appropriate time in the appropriate context.

access of the parties to relevant information.

SPECIFIC OBJECTIONS AND RESPONSES

Response to Request No. 1

produce documents that are responsive to this Request.

Response to Request No. 2

that are responsive to this Request.

Response to Request No. 3

that are responsive to this Request.

Response to Request No. 4

that are responsive to this Request.

Response to Request No. 5

Response to Request No. 6

documents that are responsive to this Request.

Response to Request No. 7

Response to Request No. 8

that are responsive to this Request.

Response to Request No. 9

Response to Request No. 10

Response to Request No. 11

the subject of this case.

Response to Request No. 12

activities on loans that are not the subject of this case.

Response to Request No. 13

Response to Request No. 14

Response to Request No. 15

Response to Request No. 16

control of Defendants and are the subject of discovery in this case.

Response to Request No. 17

Qui Tam Case.

Response to Request No. 18

Qui Tam Case.

Response to Request No. 19

Qui Tam Case.

Response to Request No. 20

will produce documents that are responsive to this Request.

Response to Request No. 21

will produce documents that are responsive to this Request.

Response to Request No. 22

will produce documents that are responsive to this Request.

Response to Request No. 23

Plaintiffs will produce documents that are responsive to this Request.

Response to Request No. 24

will produce documents that are responsive to this Request.

All documents relating to Your allegations in paragraphs 78 through 83 of the TAC

Response to Request No. 25

that are responsive to this Request.

Response to Request No. 26

that are responsive to this Request.

All documents relating to allegations in the TAC regarding alleged fraud,

Response to Request No. 27

will produce documents that are responsive to this Request.

Response to Request No. 28

produce documents that are responsive to this Request.

Response to Request No. 29

of the recipient’s identity.

Response to Request No. 30