MERIDIAN FORECLOSURE SERVICE as Trusty

CORPORATION DBA MERIDIAN TRUST DEED SERVICE

3 SAN JOAQUIN PLAZA, SUITE 215, NEWPORT BEACH, CA 92660
APN Number: 4360004-175
Trustee Sale No. 10CA00515
Title Order No. 100444358-CA-MAI
Property Address: 10751 WILSHIRE BLVD. #1402, LOS ANGELES, CA 90024
Deutsche Bank National Trust Company, as Trustee of the IndyMac INDX Mortae !oan
Trust "##$%A&II, Mortae Pass%Throuh Certificate 'eries "##$%A& (( under the Poolin
and 'er)icin Areement dated April I, "##$,
Notice to Agent is Notice to Principal and Notice to Principal is Notice to Agent.
*ood +aith Disco)ery Notice: ,erification of Proof of Claim &e-uested
12/12/2013
Dear Custodian of records,
Under the Truth in ending Act pursuant to 15 USC 1601-1667j !full disclosure", # ha$e a right
to %no& &ho the true part' of interest in this transaction is. As such, # a( as%ing 'ou to stipulate
&hether 'ou are the holder in due course for (' pro(issor' note. #f 'ou are not the holder, then
'ou ad(it responsi)ilit' to )ring the ser$icer of this o)ligation.
Please also stipulate for the record &hether or not (' loan has )een securiti*ed, and if so, the
na(e of the +,-#C/Trust (' loan is )undled &ith.
Pursuant of U.C.C. . A+T#C, 3 ./3.001 !)" 2 !1", # a( entitled to de(and presentation of the
negotia)le instru(ent. That de(and is here)' ordered. # de(and that 'ou present for ('
$isual inspection M. /&I*INA! 01T IN2 'I*NAT3&1 P&/MI''/&. N/T1 and Allone
toether 4ith the /&I*INA! 01T IN2 Deed of Trust in !os Aneles County. This is
re1uired to esta)lish 'our right of enforce(ent as 2older in Due Course $ia a chain of
assign(ent as e$idenced )' the Note or Allonge. Clai(ing to )e the 3the holder in due course4
as a state(ent is insufficient proof of status and is/&ill )e re5ected. A photocop' of the
docu(ents is insufficient proof as it does not ans&er the 1uestion of &ho CU++,NT6 is the
rightful and la&ful holder in Due Course.
#f 'ou are una)le to pro$ide this proof as # ha$e re1uested &ithin 30 da's, then you admit to
not 5ein a party of interest and cannot rightfull' enforce 'our clai( under U.C.C. . A+T#C,
3 / 3.301.
Under Title 12 / 227.38 !regulation 9" part !a", a ser$icer does not ha$e the rights of a holder in
due course and therefore, do not ha$e the right to foreclose. 6ou are here)' gi$en notice that
an' atte(pt to foreclose on (' propert' &ill )e construed as pri(a facial e$idence that 'ou are
co((itting fraud.
#n a recent case la&, it &as ruled as follo&s:
It is the creditors responsibility to keep a borrower and the Cort in!or"ed as to who
owns the note and "ort#a#e and is ser$icin# the loan% not the borrowers or the Corts
responsibility to !erret ot the trth&
It is worth repeatin# as a warnin# to lenders and ser$icers that the rles o! this Cort
apply to the"' (heir pri$ate a#ree"ents and the !ren)ied tradin# "arket !or "ort#a#es
do not e*cse co"pliance with +ankrptcy ,les any "ore than they wold jsti!y
i#norin# the +ankrptcy Code'
!#n re Nose%, ;07 <.+. ;3;, ;;0 !D.-ass 2008" )an%ruptc' trial court decision"
Under U= Code T#T, 10 > C2APT,+ ;1 > =U<C2APT,+ ? > / 1782g part )", this de)t is
no& officiall' in dispute. <' la&, all collection acti$ities (ust cease until this (atter is resol$ed.
6ou are here)' gi$en notice. <latant disregard for this la& is su)5ect to fines )' the @TC. 6ou
are ad$ised to consult legal council on this (atter.
Please )e a&are that 'our failure to $alidate this alleged de)t, it is uncollecti)le, and all
collection acti$it' (ust cease i((ediatel'. #n addition, 'our fir( should report to the credit
)ureaus that # a( not lia)le for the de)t, and an' infor(ation on (' credit report relating to this
de)t should )e re(o$ed in a ti(el' (anner.
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.
ANS!"#
$. %or each of the above persons please state whether they have personal &nowledge regarding the sub'ect
loan transaction.
ANS!"#
(. Please state the date of the first contact beneficiary )ompany and the borrower in the sub'ect loan
transaction, the name, address and telephone number of the person(s) in your company who was*were
involved in that contact.
ANS!"#
+. Please identify the person(s) involved in the underwriting of the sub'ect loan. ,-nderwriting, 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.
ANS!"#
.. Please identify any person(s) who had any contact with any third party regarding the securiti/ation,
sale, transfer, assignment, hypothecation or any document or agreement, oral, written or otherwise, that
would affect the funding, closing, or the receipt of money from a third party in a transaction that referred
to the sub'ect loan.
ANS!"#
0. Please identify any person(s) &nown or believed by anyone at as beneficiary 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, 1rust Agreement, letters or email or fa2es of transmittals including attachments) that refers
to or incorporates terms regarding the securiti/ation, sale, transfer, assignment, hypothecation or any
document or agreement, oral, written or otherwise, that would affect 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 sub'ect loan.
ANS!"#
3. Please identify all persons &nown or believed by anyone in 4ne est 5an&. %S5 or any affiliate to
have participated in the securiti/ation of the sub'ect loan including but not limited to mortgage
aggregators, mortgage bro&ers, financial institutions, Structured 6nvestment 7ehicles, Special Purpose
7ehicles, 1rustees, 8anagers of derivative securities, managers of the company that issued an Asset9
bac&ed security, -nderwriters, "ating Agency, )redit !nhancement Provider.
ANS!"#
:. Please identify the person(s) or entities that are entitled, directly or indirectly to the stream of revenue
from the borrower in the sub'ect loan.
ANS!"#
1; Please identify the person(s) in custody of any document that identifies the loan servicer(s) in the
sub'ect loan transaction.
ANS!"#
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 sub'ect loan transaction.
ANS!"#
1$. 4ther than people identified above, identify any and all persons who have or had personal &nowledge
of the sub'ect loan transaction, underwriting of the sub'ect loan transaction, securiti/ation, sale, transfer,
assignment or hypothecation of the sub'ect loan transaction, or the decision to enforce the note or
mortgage in the sub'ect loan transaction.
ANS!"#
1(. Please state address, phone number, and employment history for the past ( years of 1amara Price, 7ice
President, 4ne est 5an&. %S5 <designated as the Assignor= of the mortgage loan to >eutsche 5an&
National 1rust )ompany (Assignment of 8ortgage)
ANS!"#
1?. Please state the date on which original beneficiary, (originator) sold the mortgage loan to 4ne est
5an&. %S5 (Seller and 8aster Servicer).
ANS!"#
1+. Please state the date on which 4ne est 5an&. %S5 (Seller and 8aster Servicer) sold the mortgage
1.. >id 4ne est 5an&. %S5 (originator) or previous servicers of this account receive any compensation,
fee, commission, payment, rebate or other financial considerations from 4ne est 5an&. %S5 (Seller and
8aster Servicer) or any affiliate or from the trust funds, for handling, processing, originating or
administering this loan@
ANS!"#
10. 6f yes, please describe and itemi/e each and every form of compensation, fee, commission, payment,
rebate or other financial consideration paid to 4ne est 5an&. %S5 the originator or previous servicers of
this account by 4ne est 5an&. %S5 or any affiliate, or from the trust fund.
ANS!"#
13. Please identify any party, person or entity &nown or suspected 4ne est 5an&. %S5 or any of your
officers, employees, independent contractors or other agents, or servants of your company who might
possess or claim rights under the sub'ect loan or mortgage and*or note.
ANS!"#
1:. Please identify the custodian of the records that would show all entries regarding the flow of funds for
the sub'ect loan transaction prior to and after closing of the loan. (%low of funds, means any record of
money received, any record of money paid out and any boo&&eeping or accounting entry, general ledger
and accounting treatment of the sub'ect loan transaction at your company or any affiliate including but not
limited to whether the sub'ect 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
reAuirements of your company or any affiliate.)
ANS!"#
$;. Please identify the auditor and*or accountant of your financial statements or ta2 returns.
ANS!"#
$1. Please identify any attorney with whom you consulted or who rendered an opinion regarding the
sub'ect loan transaction or any pattern of securiti/ation that may have affected the sub'ect loan transaction
directly or indirectly.
ANS!"#
$$. Please identify any person who served as an officer or director with >eutsche 5an& National
)ompany or 4ne est 5an&. %S5 commencing with . months prior to closing of the sub'ect loan
transaction through the present. (1his interrogatory is limited only to those people who had &nowledge,
responsibility, or otherwise made or received reports regarding information that included the sub'ect loan
transaction, and*or the process by which solicitation, underwriting and closing of residential mortgage
loans, or the securiti/ation, sale, transfer or assignment or hypothecation of residential mortgage loans to
third parties.)
ANS!"#
$(. >id any investor*certificate holder approve or authori/e foreclosure proceedings on BBBCs property@
ANS!"#
$?. Please identify the person(s) involved or having &nowledge of any insurance policy or product, plan or
instrument describing over9collaterali/ation, cross9collaterali/ation or guarantee or other instrument
hedging the ris& 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 sub'ect 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.)
ANS!"#
$+. Please identify the person(s) involved or having &nowledge of any credit default swap or other
instrument hedging the ris& of default as to any person or entity acting as an issuer of any securities or
certificates. (Such instrument(s) relate to the composition of a pool, tranche or other aggregation of assets
that was created, included or referred to the sub'ect loan.)
ANS!"#
# a( gi$ing 'ou for(al notice that failure to respond to this letter through a $erified and $alidated
proof of clai( &ithin 30 da's as # ha$e as%ed for, point for point &ill )e ta%en as an
ad(inistrati$e default.
Please )e ad$ised. A C/P. of the said Note nor an Affida)it of !oss or any other forms
4ill not 5e accepta5le.
Please contact (e in &riting to arrange for an appropriate point of inspection in <e$erl' hills
California
itigation is $er' eApensi$e and should )e a$oided at all cost. This is (' good faith atte(pt to
resol$e this (atter )efore # a( forced to litigate against 'our co(pan'. # a( pleading &ith 'ou
to resol$e this (atter pri$atel' and ci$ill' as to a)oid 5urdenin our courts 4ith this matter6
If I ha)e to, I 4ill see you in court6 This is not an idle threat6
Please take this matter seriously6
Armond Trakarian Esshagh Younai
Armond Trakarian/ attorney in fact owner and trustor