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Plaintiff, US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR GSMPS 2004-4, by and through
its undersigned counsel, files this Motion to Compel production of documents, answers to Interrogatories and
answers to Request for Admissions and as grounds therefore states as follows:
1. The Plaintiff propounded Interrogatories, Request for Production and Request for Admissions on
or about August 17,2009. Defendant had until September 22,2009, within which to respond to the above-
referenced discovery.
2. Plaintiff contacted counsel for the Defendant to make a good faith effort to obtain the requested
outstanding discovery responses and to date, Plaintiff has not received the requested responses from the Defendant.
WHEREFORE, the Plaintiff respectfully requests this Court enter an Order Compelling the Production of
Documents, answers to Interrogatories and answers to Request for Admissions referenced above as well as award
Plaintiff reasonable attorney's fees and costs as a result of this motion.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail on this
--1- day of October, 2009, to all parties on the attached service list.
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r>. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY, FLORIDA
CIVIL ACTION
US BANK NATIONAL ASSOCIATION, AS TRUSTEE
FOR GSMPS 2004-4,
Plaintiff,
CASE NO.: 36-2008-CA-055974
vs. DIVISION: G
PLEASE TAKE NOTICE that the Motion to Compel will be called up for hearing before The Honorable
MICHAEL T. MCHUGH, Judge of the above-styled Court in Chambers in the LEE County Courthouse at 1700
Monroe St. Court Room 16, 4th floor, Fort Myers, FL 33901, on February 22,2010 at 11:OOAMEST, or as soon
Please be advised that the defendant is pro-se, therefore, this hearing did not require coordination. Please be
advised that Plaintiffs counsel attempted to coordinate the above hearing with Opposing Counsel's office and was
unsuccessful after three (3) attempts, therefore, this hearing was scheduled unilaterally.
I HEREBY CERTIFY that a true and '4°OPY of the foregoing has been furnished by U.S. Mail to all
parties listed on the attached service list on this day of January, 2010.
111111111111111111111111111111111111111111111111111111I 111111111111111111111111111111111111111111111
cc: Judge's Judicial Assistant
**See Americans with Disabilities Act**
If you are a person with a disability who needs any accommodation in order to participate in this
proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Ken Kellum,
Court Operations Manager whose office is located at Lee County Justice Center, 1700 Monroe Street, Fort
Myers, Florida 33901, and whose telephone number is (239) 533-1700; within two working days of your receipt
of this notice of sale; if you are hearing or voice impared, call1-SOO-955-S771 (TDD).
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"
MINUTES
Hearing Information
r>,
C8J Motion to Compel o Granted ~ Denied o Reserved
o Motion o Granted o Denied o Reserved
o Motion o Granted o Denied o Reserved
o Other: o Granted o Denied o Reserved
Notes:
THIS CAUSE having come before the Court on February 22, 2010, on Plaintiffs Motion to Compel
and having reviewed the aforementioned documents and having heard the arguments of Plaintiffs Counsel and the
________ , 2010.
111111111111111111111111111111111111111111111111111111I 111111111111111111111111111111111111111111111
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
LEE COUNTY, FLORIDA CIVIL ACTION
MINUTES
Hearing Information