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    Document Request 01

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    osvaldo valdes
    This document is a request for production of documents from the defendant Osvaldo Valdes to the plaintiff Chase Bank USA, N.A. in a civil court case. The defendant requests 10 categories of documents from Chase Bank including any documents with the defendant's signature, documents supporting Chase Bank's denial of any admissions, records showing Chase Bank purchased the alleged debt, contracts between Chase Bank and its legal department, account ledgers for the defendant, any signed contracts between the defendant and Chase Bank for the loan or debt in question, tax records if any debt was written off, documents related to the source of funds for the disputed account, documents regarding any implication that a loan was given to the defendant, and Chase Bank's corporate charter.

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    © All Rights Reserved
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    Document Request 01

    Uploaded by

    osvaldo valdes
    20 views3 pages
    This document is a request for production of documents from the defendant Osvaldo Valdes to the plaintiff Chase Bank USA, N.A. in a civil court case. The defendant requests 10 categories of documents from Chase Bank including any documents with the defendant's signature, documents supporting Chase Bank's denial of any admissions, records showing Chase Bank purchased the alleged debt, contracts between Chase Bank and its legal department, account ledgers for the defendant, any signed contracts between the defendant and Chase Bank for the loan or debt in question, tax records if any debt was written off, documents related to the source of funds for the disputed account, documents regarding any implication that a loan was given to the defendant, and Chase Bank's corporate charter.

    Original Description:

    NYC Court Document.

    Original Title

    47075 Document Request 01

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    This document is a request for production of documents from the defendant Osvaldo Valdes to the plaintiff Chase Bank USA, N.A. in a civil court case. The defendant requests 10 categories of documents from Chase Bank including any documents with the defendant's signature, documents supporting Chase Bank's denial of any admissions, records showing Chase Bank purchased the alleged debt, contracts between Chase Bank and its legal department, account ledgers for the defendant, any signed contracts between the defendant and Chase Bank for the loan or debt in question, tax records if any debt was written off, documents related to the source of funds for the disputed account, documents regarding any implication that a loan was given to the defendant, and Chase Bank's corporate charter.

    Copyright:

    © All Rights Reserved
    Download as ODT, PDF, TXT or read online from Scribd
    Download as odt, pdf, or txt
    20 views3 pages

    Document Request 01

    Uploaded by

    osvaldo valdes
    This document is a request for production of documents from the defendant Osvaldo Valdes to the plaintiff Chase Bank USA, N.A. in a civil court case. The defendant requests 10 categories of documents from Chase Bank including any documents with the defendant's signature, documents supporting Chase Bank's denial of any admissions, records showing Chase Bank purchased the alleged debt, contracts between Chase Bank and its legal department, account ledgers for the defendant, any signed contracts between the defendant and Chase Bank for the loan or debt in question, tax records if any debt was written off, documents related to the source of funds for the disputed account, documents regarding any implication that a loan was given to the defendant, and Chase Bank's corporate charter.

    Copyright:

    © All Rights Reserved
    Download as ODT, PDF, TXT or read online from Scribd
    Download as odt, pdf, or txt
    of 3

    CIVIL COURT OF THE CITY OF NEW YORK

    COUNTY OF NEW YORK


    ------------------------------------------------------------ x INDEX NO. 47075-10
    :
    CHASE BANK USA, N.A. :
    Plaintiff :
    : DEFENDANTS
    : FIRST REQUEST
    -against- : FOR PRODUCTION
    : OF DOCUMENTS
    :
    :
    :
    OSVALDO VALDES :
    Defendant :
    :
    ------------------------------------------------------------ x

    Defendant's First Request for Production of Documents

    Defendant, pursuant to R.3120 NY CPLR, request plaintiff CHASE BANK USA, N.A. to
    produce for inspection and copying the original of the following documents and things at the
    address below. If a document does not exist, you are required to state that it does not exist.
    Failure to comply fully or partially with this request within twenty (20) days after service of
    notice shall be deemed a confession that the document does not exist or that CHASE BANK
    USA, N.A. is committing fraud by concealment.

    Definitions
    a. “document” includes every piece of paper held in your possession or generated by you.
    b. “You”, “plaintiff” and “your” include CHASE BANK USA, N.A. and any and all persons
    acting for on in concert with CHASE BANK USA, N.A.

    Request for Production of Documents

    1. Original of all documents with Defendant's signature attached.

    2. If Plaintiff denied any Admissions in 'Defendant's First Request for Admissions' please furnish
    all factual evidence that support the denial.

    3. If Plaintiff is a collection agency - owner of the debt other than the original bank - furnish
    copy of original purchase document showing Plaintiff's name as purchaser, original bank as
    seller, original account number, amount of account/alleged debt, amount Plaintiff paid for
    account, date of purchase.

    47075-10 1 of 3
    4. A certified and validated copy, front and back, of the contract for services which CHASE
    BANK USA, N.A. has with Chase Legal Department.

    5. The account and general ledger or each and every contract CHASE BANK USA, N.A.
    alleges Osvaldo Valdes has with CHASE BANK USA, N.A. showing all receipts and
    disbursements and verified under penalty of perjury by an officer of CHASE..

    6. A certified and validated copy, front and back, of the signed contract CHASE BANK USA,
    N.A. alleges Osvaldo Valdes has with CHASE BANK USA, N.A. for which this lawsuit has
    commenced showing any and all assigments or allonges.

    7. If any debt has been 'charged off' by plaintiff, produce all tax records submitted to Internal
    Revenue Service showing amount received by plaintiff.

    8. Produce all records, reports, memoranda relating to the source of funds relating this disputed
    account and list all other sources of information such as computer file names and names of
    databases or locations at which related information is located or accessible.

    9. Please produce all documents and information, related in any way, to your implication or
    allegation that a loan was given to the defendant.

    10. All pages, front and back, of CHASE BANK USA, N.A. corporate charter.

    The Defendant herein reserves the right to propound additional requests for production of
    documents based upon the answers herein in furtherance of its discovery proceedings.

    Respectfully Submitted,

    By: Osvaldo Valdes, 184 East 7th Street, New York, NY [10009]

    --------------------------------------------------------------------------------
    CERTIFICATE OF SERVICE I certify that the foregoing was served by mailing a copy by

    United States mail, first-class postage prepaid, on 31th. Day of January, 2011, as follows:

    47075-10 2 of 3
    CHASE LEGAL DEPARTMENT
    1985 MARCUS AVENUE, NY2-M352
    NEW HYDE PARK, NY 11042

    __________________________
    By: Osvaldo Valdes, 184 East 7th Street, New York, NY [10009]

    47075-10 3 of 3

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