_________________________________________________________________________

SUBPOENA FOR PRODUCTION Name:

Filed on Behalf of the Defendants Address:
Form 41, Version 1
Uniform Civil Procedure Rules 1999. Phone No:
Rule 415(1); 420 Page 1 of 4
DISTRICT COURT OF QUEENSLAND

REGISTRY:
NUMBER:

Plaintiff: BANK
AND

Defendants DANY DEFENDANT

SUBPOENA FOR PRODUCTION

To: Proper Officer of XYZ CORP
ADDRESS

THE COURT ORDERS that you attend and produce this subpoena and the documents and
things described in the schedule:
(a) before the ___________;
(b) at ______________;
(c) on DATE at TIME and until you are excused from further attending.
SCHEDULE
1. All original contract or agreement document(s) that are relied upon by the Plaintiff to
demonstrate the Plaintiff has privity of contract and standing to bring and maintain this
proceeding.
2. The original alleged loan agreement the subject of this proceeding.
3. All original alleged Mortgage documents the subject of this proceeding.
4. All documents in Plaintiffs possession or available to Plaintiff that establish that the
Plaintiff is the legal, beneficial or equitable owner of the alleged loan agreement and
Mortgage that is the subject of this proceeding.
5. All documents which support Plaintiffs claim that they currently own the alleged loan
agreement and Mortgage including without limitation documents pertaining to all
transfers, assignments, mergers, purchase and sale agreements, endorsements or other
documents that demonstrate Plaintiff has standing to bring this claim at the time it was
filed.
6. All documents pertaining to the securitisation of the subject alleged loan agreement and
mortgage.
7. All documents that show the present physical location of the original alleged loan
agreement and mortgage documents claimed to be owned by the Plaintiff.
8. All documents setting forth the name, address, and telephone number of the physical

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custodian of the original alleged loan agreement and Mortgage document claimed to be
owned by the Plaintiff.
9. All documents setting forth the assignment of either the alleged loan agreement or
mortgage document which are claimed to be owned by the Plaintiff, to any particular
Special Purpose Vehicle (SPV), Specialized Investment Vehicle (SIV), Collateralized
Mortgage Obligation (CMO), Collateralized Debt Obligation (CDO), series of
residential mortgage-backed securities or certificates (RMBS), collateral default swap
(CDS), Trust, or the like used in the securitization process.
10. All documents setting forth the full name, current address, and telephone number of
each holder of or investor in any SPV, SIV, CMO, CDO, RMBS, or CDS which is
collateralized in whole or in part by the Defendants alleged loan agreement and
mortgage documents or any right incident thereto or thereunder.
11. All documents that identify the full name, current address, and telephone number of all
persons who authorized the filing of this proceeding against the Defendants.
12. All accounting records of the alleged loan in accordance with Australian Accounting
Standards and Generally Accepted Accounting Principles.
13. All accounting records that show how the alleged liability arose.
14. All documents evidencing all payments made by the Defendants or any third party on
or toward the Defendants alleged loan obligations at any time.
15. All documents setting forth any credits applied against any balance due on the
Defendants alleged loan at any time, including amount of credit, date credit applied,
source of credit, and obligation to which credit was applied (e.g. principal, interest, late
fees, etc.)
16. All documents setting forth the disposition of all payments made by the Defendants or
any third party in connection with the Defendants alleged loan, including but not
limited to documentation setting forth amounts assigned to or credited against
principal, interest, insurance premiums or payments, tax deductions or payments, late
fees, or any other charges.
17. All documents demonstrating any funding of any of the Defendants alleged loan
agreement and mortgage the subject of this action by any security.
18. All documents concerning any consideration exchanged between any persons or parties
in connection with the assignment or sale of any part of, or right under, or right
incident to the Defendants alleged loan agreement and mortgage (e.g. assignment or
sale of mortgage, assignment or sale of a note, assignment or sale of servicing rights,
assignment or sale of right to income stream from borrower payments, assignment to a
mortgage pool, assignment to any SPV, SIV, CMO, CDO, RMBS, or CDS, [as defined
herein infra], and the like).
19. All documents identifying any descriptions or legends of all codes utilised within any
mortgage servicing or accounting system identified within the response to schedule
18. above.
20. All policies of insurance, including but not limited to mortgage insurance, insurance in
favour of any trustee or loan trust, swap policies, master and bulk supplemental
policies, mortgagee title policies, or any other insurance which provides benefits to
either the Plaintiff or any party in privity with the Plaintiff or any original lender or
successor thereto or securitised trust upon default by the borrower in connection with
the Defendants alleged loan agreement and Mortgage.

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21. All documents setting forth any claims made against any policy of insurance the
subject of schedule 20. above.
22. All documents setting forth any payments made or received in connection with any
claim the subject of schedule 21. above.
23. All documents setting forth any denial or reservation of rights as to any claim made in
connection with any policy of insurance the subject of schedule 20. above.
24. All documents setting forth any servicing agreement between the plaintiff and any
entity with reference to the alleged loan agreement and mortgage of the Defendants.
25. All Pooling and Service Agreements, Custodial Agreements, Deposit Agreements,
Master Purchasing Agreements, Issuer Agreements, Commitment to Guarantee
Agreements, Release of Document Agreements, Master Agreements for Servicers
Principal and Interest Custodial Account, Servicers Escrow Custodial Account
Agreements, Release of Interest Agreements, Trustee Agreements, or the like relating
to the alleged loan agreement and Mortgage of the Defendants.
26. All documents setting forth the entire chain of title to the alleged loan agreement and
mortgage instruments of the Defendants from origination to the present.


TAKE NOTICE:
(1) failure to comply with this subpoena without lawful excuse is contempt of court and
may result in your arrest.
(2) you need not comply with this subpoena unless conduct money sufficient to meet your
reasonable expenses of complying with the subpoena is paid, or tendered to you, not
later than a reasonable time before the day on which you would be required to attend
the Court.
(3) you have the right to apply to the court to have the subpoena set aside on any sufficient
grounds including-
want of relevance; or
privilege; or
oppressiveness, including oppressiveness because substantial expenses may not be reimbursed;
or
non-compliance with the Uniform Civil Procedures Rules.
(4) if you are not a party to these proceedings, instead of attending the court you or your
agent may produce the documents and things described in the schedule to the Registry
of the Court from which the subpoena was issued, not later than the day before the day
on which you are required to attend.
(5) if you are not a party to the proceeding and you incur substantial loss or expense in
complying with this subpoena, you may apply to the Court for an order that the party
who requested the issue of the subpoena pay to you an amount in addition to conduct
money to compensate you for the loss or expense, including legal costs, incurred in
responding properly to the subpoena.


ISSUED WITH THE AUTHORITY OF THE DISTRICT COURT OF QUEENSLAND:

Signed:

Dated: ________________


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Issued at the request of the Defendants.