INSTRUCTIONS

a. These Interrogatories are continuing in character so as to require you to file supplementary

answers if you obtain further or different information before trial.
b. Where name and identity of a person is required, please state full name, home address and also
business address, if known.
c. Where knowledge or information in possession of a party is requested, such request includes
knowledge of the party's agents, representatives, and unless privileged, his attorney's. When
answer is made by corporate defendant, state the name, address and title of persons supplying the
information and making the affidavit, and announce the source of his or her information.
d. The pronoun "you" refers to the party to whom the Interrogatories are addressed and the
parties mentioned in clause (d).
e. "Identify" when referring to an individual, corporation, or other entity shall mean to set forth
the name and telephone number, and if a corporation or other entity, its principle place of
business, or if an individual, the present or last known home address, his or her job title or titles,
by whom employed and address of the place of employment.

INTERROGARTORY NO. 1: Identify the person or persons answering these interrogatories.

Include their business address, business phone number, and title within the Plaintiff’s
Organization.

INTERROGARTORY NO. 2: Identify all persons known to you who have knowledge of facts
relevant to this case, including but not limited to all persons interviewed by you, by your
counsel, or by any person cooperating with you in the defense of this action, and state the subject
matter of testimony, giving a brief description thereof, for each person you may call as a witness
in this case.

INTERROGARTORY NO. 3: State your full name, your business purpose, (e.g. Creditor,
Lender, Collection Agency, etc.) and your form of Business organization (e.g. corporation,
partnership, sole proprietorship, etc.)

INTERROGARTORY NO. 4: Identify all documents or other tangible evidence that support
your contention that the Defendant, for valuable consideration received, entered into a contract
promising to pay the Plaintiff or the Plaintiff’s assignor.

INTERROGARTORY NO. 5: In regards to the contract or agreement alleged in this action,

please state the following:
A) Terms of the contract or agreement
B) Credit limit or amount financed in the alleged contract or agreement.
C) Date and monetary value of any credit transactions alleged to be executed on the contract or
agreement
D) Date and monetary value of any valuable consideration received on the contract or agreement
E) Date and monetary value of any payments or credits alleged to be executed on the contract or
agreement.

INTERROGATORY NO. 6: If the alleged subject of this action is a contract or agreement

originating between the Defendant and a party not subject to this action, state the following:
A) Creditor name
B) Creditor Address
C) Creditor account or reference number for the subject of this action
D) State all facts in support of your contention that the alleged contract or agreement was
transferred or assigned to the Plaintiffs
E) Identify all witnesses with evidence in support of your contention that the alleged contract or
agreement was transferred or assigned to the Plaintiffs
F) Identify all documents or other tangible evidence that support your contention that the alleged
contract or agreement was transferred or assigned to the Plaintiffs

INTERROGATORY NO. 7: For each person who has had any involvement in any manner in any
efforts on your behalf to collect or attempt to collect any debt(s) purportedly owing by
Defendant, state his/her name, position, work address and telephone numbers, and the nature and
purpose of his/her involvement.

INTERROGARTORY NO. 8: Describe each action taken, the nature, contents and subject
matter of each discussion or conversation held, and the time, place and the date of each such
action or conversation; and identify all documents relevant, related to or reflecting said
involvement of each such person.

INTERROGARTORY NO. 9: Describe the maintenance of all procedures utilized by you, at any
time from March 30, 2007, the date account was alleged opened with Providian National Bank,
through the present to assure accuracy against violations of the Fair Debt Collection Practices
Act.

INTERROGARTORY NO. 10: Describe the maintenance of all procedures utilized by you, at
any time from March 30, 2007, the date account was alleged opened with BANK, through the
present to assure accuracy against violations of the Massachusetts Code of Civil Procedures.

INTERROGARTORY NO. 11: Describe the maintenance of all procedures utilized by you at
any time from March 30, 2007 the date account was alleged opened with Bank, through the
present to assure accuracy against violations of the Massachusetts Credit Law.

INTERROGARTORY NO. 12: Identify the persons or entities, which are the creditor(s)
regarding any debt(s), which you have attempted to collect from Defendant, identify all
documents related or relevant to your contractual agreement(s) (Servicing, Assignment(s), etc.),
or other business relationships with said persons or entities.

INTERROGARTORY NO. 13: Identify each person who has had any contact or communication
on your behalf with said persons or entities regarding Defendant or Defendant’s purported
debt(s), state when, how, where, and with whom said contact or communication occurred and in
detail and with particularity the substance thereof.

INTERROGARTORY NO. 14: Describe all collection activities, which you were authorized to
perform by the creditor, and identify the terms of the agreement between the creditor(s) and you
pursuant to which you sought to collect this account.

INTERROGARTORY NO. 15: To the extent not previously done, identify all documents
relevant, related to, or reflecting any aspect of any efforts undertaken by you to collect any
debt(s) from Defendant, or to any debt(s) purportedly owed by Defendant to you or to the
underlying creditor(s).

INTERROGARTORY NO. 16: Describe your procedure and policy with respect to the
Maintenance, preservation, and destruction of documents, stating in your Answer whether any
documents or things relating to any information Requested in these interrogatories, or related in
any way to this lawsuit, have ever been destroyed or are no longer in your custody. For each such
document, please identify the document, how, when and why each document was destroyed or
otherwise left your control, the identity of any person who participated in any way in the
destruction and/or action for destroying the document or to transfer it out of your control or
custody; and if the document still exists, identify the person now having control or custody of the
document.

INTERROGARTORY NO. 17: State all facts in support of your contention that the Defendant,
for valuable consideration received, entered into a contract promising to pay the Plaintiff.

INTERROGARTORY NO. 18: Identify all witnesses with evidence in support of your
contention that the Defendant, for valuable consideration received, entered into a contract
promising to pay the Plaintiff.

INTERROGARTORY NO. 19: Identify the relationship between you and Bank, with regards to
the legal relation with one another, revenue sharing, and contractual agreements.

INTERROGARTORY NO. 20: Identify the relationship between you and Midland Credit
Management, with regards to the legal relation with one another, revenue sharing, and
contractual agreements.

INTERROGARTORY NO. 21: State if you has a legal department and if so, identify the location
of the legal department, the dates the legal department has been in existence, the names,
positions, telephone numbers and credentials off all employees in the legal department.

INTERROGARTORY NO. 22: Identify the names, addresses, and telephone numbers of all
persons who have supplied any information contained in Plaintiff’s Claim.

INTERROGARTORY NO. 23: Identify all documents that the Plaintiff’s collectively intent to
rely upon as a defense in this Counter-Claim.

INTERROGARTORY NO. 24: Identify all recordings you ever possessed in relation to
Defendant of this action.

INTERROGARTORY NO. 25: State all actions taken to verify the accuracy and completeness of
the accounts reported and state your procedures designed to assure the maximum possible
accuracy of the information reported by you, the Plaintiff.

INTERROGARTORY NO. 26: State completely the factual basis of each defense, which you
now assert or will assert in this action.

INTERROGARTORY NO. 27: State all the facts that show that the complaint fails to state a
claim upon which relief may be granted, that Defendants claims fail and are barred against
Plaintiff by the doctrine of unclean hands and that there has been a failure to comply with
pertinent provisions of the Massachusetts Code of Civil Procedure.

Possible interrogatories that you might ask if being sued for debt -- remember that these are just
suggestions and may not apply to your case. Also, there may be other questions that are more
pertinent to your case - only you can decide what will work best for you:

--What date (day/month/year) did the plaintiff acquire this debt?

--At what price did the plaintiff acquire this debt? [I'm not sure if this question is permissible or
valid as it might reveal trade secrets or be irrelevant to the case, but I asked it in one of my
cases -- I'll keep you posted!]

--From whom did the plaintiff acquire this debt? If from the original creditor, list the name,
address, phone number and account number. If not from the original creditor, list the name,
address and phone number of the person or entity from which it was purchased.

--Please provide the name, business phone number, title, years with the company as well as years
of experience in their field of the person or persons responsible for the books and records of the
defendant.

--What training and education are required by the person or persons responsible for the books
and records of the defendant in order to perform their job adequately, efficient and competently?
[I think this question is important because is the person who oversees the books an accountant?
A lawyer? A layperson? Do they have college education? High school diploma? Any education?
What makes them competent to attest that the amount owed and records are accurate, just and
proper?]

--When was the last payment made to the account and for what amount? [This is important,
especially if you know the last date the payment was made -- you can then watch to see if the
plaintiff lies. Also, if they are truthful, this will help you in determining the statute of limitations.]

--The FDCPA requires that you notify consumers within five days of the initial communication
to enable them to validate the debt (Section 809). How many attempts did you make to reach the
consumer by phone? How many attempts did you make by mail, first-class, certified, express or
other? Did you send the initial written communication by any trackable means to demonstrate
that it was indeed received by the defendant? If so, what date was it received by the defendant?
What phone number did you use to reach the defendant?

INSTRUCTIONS

ii). These requests for interrogatories are directed toward all information known or available to
Deutsche Bank National Trust Company – not its lawyer, Ralph F. Casale, Esq. – including
information contained in the records and documents in Deutsche Bank National Trust
Company’s custody or control or available to Deutsche Bank National Trust Company upon
reasonable inquiry.

iii). Each request for interrogatory is to be deemed a continuing one. If, after serving an answer,
you obtain or become aware of any further information pertaining to that request, you are
requested to serve a supplemental answer setting forth such information.

iv). As to every request for interrogatory which an authorized officer of Deutsche Bank National
Trust Company fails to answer in whole or in part, the subject matter of that request will be
deemed confessed and stipulated as fact to the Court.

v). Kindly attach additional sheets as required identifying the Interrogatory being answered. You
have a continuing obligation to update the information in these Interrogatories as you acquire
new information. If no such update is provided in a reasonable period of time that you acquired
such information, it may be excluded at trial or hearing.

DEFINITIONS

vi). “You” and “your” include Deutsche Bank National Trust Company and any and all persons
acting for or in concert with Deutsche Bank National Trust Company.

vii). “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 document within the meaning of this term. The term “document”
also includes any “tangible things” as that term is used in Rule 34(a).

viii). Parties. The term “plaintiff” or “defendant”, as well as a party’s full or abbreviated name or
a pronoun referring to a party, means the party and, where applicable, (his/her/its) agents,
representatives, officers, directors, employees, partners, corporate parent, subsidiaries, or
affiliates.

ix). 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, telephone 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.

x). Identify (document). When referring to a document, “identify” means to give, to the extent
known, the following information: (a) the type of document; (b) the general subject matter of the
document; (c) the date of the document; (d) the authors, address, and recipients of the document;
(e) the location of the document; (f) the identity of the person who has custody of the document;
and (g) whether the document has been destroyed, and if so, (i) the date of its destruction, (ii) the
reason for its destruction, and (iii) the identity of the person who destroyed it.

xi). Relating. The term “relating” means concerning, referring, describing, evidencing, or
constituting, directly or indirectly.

xii). 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 reasons that might otherwise be
construed to be outside of its scope.

REQUEST FOR INTERROGATORIES

1. Please identify each person who answer these interrogatories and each person (attach pages if
necessary) who assisted, including attorneys, accountants, employees of third party entities, or
any other person consulted, however briefly, on the content of any answer to these
interrogatories.

ANSWER:

2. For each of the above persons please state whether they have personal knowledge regarding
the subject loan transaction.

ANSWER:

3. Please state the date of the first contact between Deutsche Bank National Trust Company and
the borrower in the subject loan transaction, the name, address and telephone number of the
person(s) in your company who was/were involved in that contact.

ANSWER:

4. Please identify every potential party to this lawsuit.

ANSWER:

5. Please identify the person(s) involved in the underwriting of the subject loan. “Underwriting”
refers to any person who made representations, evaluations or appraisals of value of the home,
value of the security instruments, and ability of the borrower to pay.

ANSWER:
6. Please identify any person(s) who had any contact with any third party regarding the
securitization, sale, transfer, assignment, hypothecation or any document or agreement, oral,
written or otherwise, that would effect the funding, closing, or the receipt of money from a third
party in a transaction that referred to the subject loan.

ANSWER:

7. Please identify any person(s) known or believed by anyone at Deutsche Bank National Trust
Company who had received physical possession of the note and allonges, the mortgage, or any
document (including but not limited to assignment, endorsement, allonges, Pooling and
Servicing Agreement, Assignment and Assumption Agreement, Trust Agreement, letters or
email or faxes of transmittals including attachments) that refers to or incorporates terms
regarding the securitization, sale, transfer, assignment, hypothecation or any document or
agreement, oral, written or otherwise, that would effect the funding, or the receipt of money from
a third party in a transaction, and whether such money was allocated to principal, interest or
other obligation related to the subject loan.

ANSWER:

8. Please identify all persons known or believed by anyone in Deutsche Bank National Trust
Company or any affiliate to have participated in the securitization of the subject loan including
but not limited to mortgage aggregators, mortgage brokers, financial institutions, Structured
Investment Vehicles, Special Purpose Vehicles, Trustees, Managers of derivative securities,
managers of the company that issued an Asset-backed security, Underwriters, Rating Agency,
Credit Enhancement Provider.

ANSWER:

9. Please identify the person(s) or entities that are entitled, directly or indirectly to the stream of
revenue from the borrower in the subject loan.

ANSWER:

10 Please identify the person(s) in custody of any document that identifies the loan servicer(s) in
the subject loan transaction.

ANSWER:

11. Please identify any person(s) in custody of any document which refers to any instruction or
authority to enforce the note or mortgage in the subject loan transaction.

ANSWER:

12. Other than people identified above, identify any and all persons who have or had personal
knowledge of the subject loan transaction, underwriting of the subject loan transaction,
securitization, sale, transfer, assignment or hypothecation of the subject loan transaction, or the
decision to enforce the note or mortgage in the subject loan transaction.

ANSWER:

13. Please state address, phone number, and employment history for the past 3 years of Tamara
Price, Vice President, Argent Mortgage Company, LLC, “designated as the Assignor” of the
mortgage loan to Deutsche Bank National Trust Company (Assignment of Mortgage recorded in
Essex County Register’s Office on June 25, 2008).

ANSWER:

14. Please state the date on which Argent Mortgage Company, LLC (originator) sold the
mortgage loan to Ameriquest Mortgage Company (Seller and Master Servicer).

ANSWER:

15. Please state the date on which Ameriquest Mortgage Company (Seller and Master Servicer)
sold the mortgage loan to Argent Securities, Inc. (Depositor).

ANSWER:

16. Did Argent Mortgage Company, LLC (originator) or previous servicers of this account
receive any compensation, fee, commission, payment, rebate or other financial considerations
from Ameriquest Mortgage Company (Seller and Master Servicer) or any affiliate or from the
trust funds, for handling, processing, originating or administering this loan?

ANSWER:

17. If yes, please describe and itemize each and every form of compensation, fee, commission,
payment, rebate or other financial consideration paid to Argent Mortgage Company, LLC, the
originator or previous servicers of this account by Ameriquest or any affiliate, or from the trust
fund.

ANSWER:

18. Please identify any party, person or entity known or suspected by Deutsche Bank National
Trust Company or any of your officers, employees, independent contractors or other agents, or
servants of your company who might possess or claim rights under the subject loan or mortgage
and/or note.

ANSWER:

19. Please identify the custodian of the records that would show all entries regarding the flow of
funds for the subject loan transaction prior to and after closing of the loan. (Flow of funds, means
any record of money received, any record of money paid out and any bookkeeping or accounting
entry, general ledger and accounting treatment of the subject loan transaction at your company or
any affiliate including but not limited to whether the subject loan transaction was ever entered
into any category on the balance sheet at any time or times, whether any reserve for default was
ever entered on the balance sheet, and whether any entry, report or calculation was made
regarding the effect of this loan transaction on the capital reserve requirements of your company
or any affiliate.)

ANSWER:

20. Please identify the auditor and/or accountant of your financial statements or tax returns.

ANSWER:

21. Please identify any attorney with whom you consulted or who rendered an opinion regarding
the subject loan transaction or any pattern of securitization that may have effected the subject
loan transaction directly or indirectly.

ANSWER:

22. Please identify any person who served as an officer or director with Deutsche Bank National
Company or Argent Mortgage Company LLC commencing with 6 months prior to closing of the
subject loan transaction through the present. (This interrogatory is limited only to those people
who had knowledge, responsibility, or otherwise made or received reports regarding information
that included the subject loan transaction, and/or the process by which solicitation, underwriting
and closing of residential mortgage loans, or the securitization, sale, transfer or assignment or
hypothecation of residential mortgage loans to third parties.)

ANSWER:

23. Did any investor/certificate holder approve or authorize foreclosure proceedings on XXX’s
property?

ANSWER:

24. Please identify the person(s) involved or having knowledge of any insurance policy or
product, plan or instrument describing over-collateralization, cross-collateralization or guarantee
or other instrument hedging the risk of default as to any person or entity acting as an issuer of
any securities or certificates. (Such instrument(s) relate to the composition of a pool, tranche or
other aggregation of assets that was created, included or referred to the subject loan and the pool
or aggregation was transmitted, transferred, assigned, pledged or hypothecated to any entity or
buyer. A person who “transmitted, transferred, assigned, pledged or hypothecated” refers to any
person who suggested, approved, received or accepted the composition of the pool or
aggregation made or confirmed representations, evaluations or appraisals of value of the home,
value of the security instruments, ability of the borrower to pay.)

ANSWER:
25. Please identify the person(s) involved or having knowledge of any credit default swap or
other instrument hedging the risk of default as to any person or entity acting as an issuer of any
securities or certificates. (Such instrument(s) relate to the composition of a pool, tranche or other
aggregation of assets that was created, included or referred to the subject loan.)

ANSWER: