When you are served a Complaint for Foreclosure, you must answer within a specified number of days. Within your Answer you can make a Counterclaim. Whether you make a counterclaim or not, its good to do discovery right after you file your Answer.
Discovery is a powerful tool in a legal proceeding. It is your chance to get answers and documents to prove your side of the case.
Admissions are a particularly powerful tool because if they are ignored for more than the time allotted for a response, you can ask the court to deem them admitted.
You may feel hopelessly overwhelmed if foreclosure is filed against your home. That’s understandable. But there are steps you can take, to include discovery and requesting Admissions, which may help you keep your home.
A bank like Wells Fargo wants to make you feel guilty for not paying according to the terms of your contract, that is, your mortgage, but at the same time the bank feels that it is above the law and can use fraud and deception to take your home as if by law, but in actual fact, in total disregard for the basic principles of justice.
In the fight against foreclosure you need to arm yourself with Discovery, and in Discovery, Requests for Admissions are a big gun.
In my case, after I sent Wells Fargo my Requests for Admissions, Wells Fargo pretended to give me a HAMP loan modifiation. The tactic was meant to stop the case for awhile this allowing Wells Fargo to avoid answering the Requests for Admissions without the Court deeming the requests Admitted.
10/14/2017 ~ The judge decided for Wells Fargo. As far as I know he has not once decided for a home owner. I was super depressed. But, people have started donating to help me retain an appeals lawyer… I did a video for my Go Fund Me page. Take a look.
FIRST JUDICIAL DISTRICT COURT
COUNTY OF SANTA FE
STATE OF NEW MEXICO
Wells Fargo Bank NA,
Plaintiff,
v. No. D-101-CV-200800942
Karen Marie Kline, Pueblos de Rodeo Road Owners
Association, Inc.; Manhattan Condominium Association,
Defendants.
.
DEFENDANT KAREN MARIE KLINE’S REQUESTS FOR
ADMISSIONS PURSUANT TO RULE 1-036 TO PLAINTIFF
WELLS FARGO BANK NA
DEFINITIONS
Documents: The word “documents” where it appears herein means written, printed, typed, recorded or graphic matter of every type and description, however and by whomever prepared, produced, reproduced, disseminated, or made, in any form, which is or was in Defendant’s actual or constructive possession, custody or control, as defined in paragraph 2, below, including, but not limited to, all writings, letters, minutes, correspondence, telegrams, emails, bulletins, charts, diagrams, literature, brochures, work assignments, reports, evaluations, memoranda, notations of telephone or personal conversations, conferences or meetings, contracts, agreements, interoffice communications, notes, notebooks, diaries, drafts, worksheets, data sheets, data compilations, EDP printouts, microfilm, microfiche, circulars, pamphlets, studies, test results, notices, summaries, books, invoices, graphs, blueprints, specifications, engineering drawings, labels, photographs, phonograph records, tapes, sound recordings, films, slides, video tapes, speeches, computer files or disks, and any other writing or data storage method from which information can be obtained or translated through detection devices into reasonably usable
form, or any other tangible thing. The term “document” shall also mean each copy which is not identical to the original or to any other identified copy.
2. Plaintiff, You, Your, Yours, Wells Fargo: the words “Plaintiff”, “you”, “your”, “yours” or “Wells Fargo” shall mean Wells Fargo Bank NA, or any of its predecessors, successors, or affiliated business entities andlikewise shall mean any other individuals or entities or persons who have acted as agent of or under the direction of Wells Fargo Bank NA.
3. Me, Mine, My, I, Karen Kline, Karen Marie Kline, Karen M. Kline: the words “me”, “mine”, “my”, “I”, “Karen Kline”, “Karen Marie Kline”,or “Karen M. Kline” shall mean the Defendant in this case, Karen MarieKline.
Please admit or deny each of the following requests for admissions pursuant to Rule 1-036 NMRA, and to the extent that any of your responses is other than an unqualified admission, list all facts on which you based any part of your response that is not an unqualified admission, identify all documents memorializing each such fact, and identify all persons with knowledge of each such fact:
ADMISSIONS REQUESTED
1. Admit or Deny that Wells Fargo never at any time took possessionof the original promissory note obligating Karen Kline and/or alienable in this instant case.
ADMITTED_______ DENIED________
2. Admit or Deny that Wells Fargo is not in possession of the account and general ledger statement, authenticated by a competent fact witness, proving a deficiency owed by Karen Kline.
ADMITTED_______ DENIED________
3. Admit or Deny that absent possession of the account and general ledger statement, authenticated by a competent fact witness, proving a deficiency owed by Karen Kline, Wells Fargo cannot prove a deficiency owed by Karen Kline.
ADMITTED_______ DENIED________
4. Admit or Deny that it is a practice of Wells Fargo to charge-off and sell notes in arrears after collecting insurance on the outstanding
amount of indebtedness.
ADMITTED_______ DENIED________
5. Admit or Deny that after Wells Fargo charges-off and sells evidence of indebtedness, the commercial paper illustrating the duty between the mortgagor and mortgagee or assignee becomes legally uncollectible.
ADMITTED_______ DENIED________
6. Admit or Deny that Wells Fargo is a real party of interest in these proceedings.
ADMITTED_______ DENIED________
7. Admit or Deny that Wells Fargo received TARP funds or federal bailout funds for the subject note.
ADMITTED_______ DENIED________
8. Admit or Deny that Wells Fargo has received funds from various sources which has paid the note in full and multiple times over.
ADMITTED_______ DENIED________
9. Admit or Deny that Wells Fargo has received funds from various sources, such as TARP and federal bailout funds and insurance, which has paid for the subject note in full and that no monies are due from Karen Kline.
ADMITTED_______ DENIED________
10. Admit or Deny that Wells Fargo provided payments or transfers of funds to investors from proceeds received from any payments made by Karen Kline toward the alleged mortgage.
ADMITTED_______ DENIED________
11. Admit or Deny that Wells Fargo never provided to Karen Kline the identifications of any investors who purchased the securitized mortgage obligation which evolved from the subject loan.
ADMITTED_______ DENIED________
12. Admit or Deny that Wells Fargo has been unjustly enriched with respect to subject mortgage loan.
ADMITTED_______ DENIED________
13. Admit or Deny that Karen Kline is entitled to compensatory and general damages and for other and further equitable relief, declaratory relief and legal damages as permitted by law in this matter.
ADMITTED_______ DENIED________
14. Admit or Deny that Wells Fargo was not a participant in civil conspiracy with respect to the subject mortgage loan
ADMITTED_______ DENIED________
15. Admit or Deny that Wells Fargo did not participate in CDS (Credit Default Swaps) with respect to subject loan.
ADMITTED_______ DENIED________
16. Admit or Deny that Wells Fargo did not receive insurance funds from AIG with respect to subject loan.
ADMITTED_______ DENIED________
17. Admit or Deny that Wells Fargo did not utilize MERS with respect to subject loan.
ADMITTED_______ DENIED________
18. Admit or Deny that Wells Fargo did not utilize an MDC (Master Document Custodian) with respect to subject loan.
ADMITTED_______ DENIED________
19. Admit or Deny that Wells Fargo has an employee who is the assigned as a MDC (Master Document Custodian) with respect to subject loan.
ADMITTED_______ DENIED________
20. Admit or Deny that Wells Fargo did not sign a Pooling & Servicing Agreement with respect to subject loan.
ADMITTED_______ DENIED________
21. Admit or Deny that Wells Fargo utilizes a third party entity as the MDC (Master Document Custodian) with respect to subject loan.
ADMITTED_______ DENIED________
22. Admit or Deny that Wells Fargo has knowledge of a Pooling & Servicing Agreement which exists and the subject loan is governed by or included within this Pooling & Servicing Agreement.
ADMITTED_______ DENIED________
23. Admit or Deny that Wells Fargo does not have a purchase and sale agreement for subject loan.
ADMITTED_______ DENIED________
24. Admit or Deny that Wells Fargo does not have a record of the disbursement of funds for the acquisition of the note.
ADMITTED_______ DENIED________
25. Admit or Deny that Wells Fargo did receive insurance funds to cover the subject loan upon default on the loan.
ADMITTED_______ DENIED________
26. Admit or Deny that Wells Fargo was a movant in any of Karen Kline’s bankruptcy proceedings.
ADMITTED_______ DENIED________
27. Admit or Deny that Wells Fargo, by its irresponsible and illegal actions, has caused great harm to Karen Kline.
ADMITTED_______ DENIED________
28. Admit or Deny that each and every notary public who notarized any of the recorded documents related to Wells Fargo’s interest in or foreclosure on subject property was an employee of Wells Fargo.
ADMITTED_______ DENIED________
29. Admit or Deny that Wells Fargo is not in possession of the original promissory note for subject loan.
ADMITTED_______ DENIED________
30. Admit or Deny that that Wells Fargo engaged in conduct, the natural consequence of which is to harass, oppress, and abuse the Defendant Kline in connection with the collection of an alleged debt.
ADMITTED_______ DENIED________
31. Admit or Deny that that Wells Fargo engaged in conduct the natural consequence of which has caused considerable harm to Karen Kline.
ADMITTED_______ DENIED________
32. Admit or Deny that it is more profitable for Wells Fargo to foreclose and collect mortgage securities insurance than it is to make the home mortgage affordable so that the family/owner can stay in their home.
ADMITTED_______ DENIED________
33. Admit or Deny that Wells Fargo is committed to helping people stay in their homes.
ADMITTED_______ DENIED________
34. Admit or Deny that the papers sent to Karen Kline on March 6, 2009, by Wells Fargo Home Mortgage regarding “Modification” reflected the US Treasury’s Home Affordable Modification Guidelines publishedMarch 4, 2009: http://www.ustreas.gov/press/releases/reports/modification_program_guidelines.pdf
ADMITTED_______ DENIED________
35. Admit or Deny that steps were taken in processing the Home Affordable Modification Request and supporting documents Karen Klinesent Wells Fargo Home Mortgage, Attn: Borrower Counseling Services, on or about March 17, 2009.
ADMITTED_______ DENIED________
36. Admit or Deny that on May 4, 2009, at about 1:37 p.m. Levinia in Wells Fargo Default Operations said in a phone conversation with Karen Kline and a Hope Now counselor that there was no “loss mitigation” on file for Karen Kline.
ADMITTED_______ DENIED________
37. Admit or Deny that on May 4, 2009, at about 1:39 p.m. Levinia in Wells Fargo Default Operations said in a conversation with Karen Kline and a Hope Now counselor that Karen Kline’s file had not been updated since 2005.
ADMITTED_______ DENIED________
38. Admit or Deny that my file wasn’t updated when I sent in my request and documentation for Home Affordable Modification on or about March 17, 2009.
ADMITTED_______ DENIED________
39. Admit or Deny that on May 20, 2009, at about 1:05 p.m., Sandra in Wells Fargo Loss Mitigation said in a conversation with Karen Kline and a Hope Now counselor that Karen Kline’s file had been “pulled back” from Liquidation on May 19, 2009.
ADMITTED_______ DENIED________
40. Admit or Deny that on May 20, 2009, at about 1:08 p.m., Sandra in Wells Fargo Loss Mitigation said in a conversation with Karen Kline and a Hope Now counselor that Karen Kline had to restart the process by having the documents faxed in again but with the current date and her signature for the current date.
ADMITTED_______ DENIED________
41. Admit or Deny that New Mexico Regulating and Licensing Department, Financial Institutions Division, has received one or more complaints about Wells Fargo refusing to give a payoff figure for mortgage loans in foreclosure.
ADMITTED_______ DENIED________
42. Admit or Deny that Wells Fargo gives its foreclosure attorneys guidelines on how to deal with Wells Fargo customers who have paid on their Wells Fargo Home Mortgages but then through adverse circumstances or otherwise have fallen behind and are in foreclosure.
ADMITTED_______ DENIED________
43. Admit or Deny that Wells Fargo has guidelines for its employees on how to deal with Wells Fargo customers.
ADMITTED_______ DENIED________
44. Admit or Deny that Wells Fargo foreclosure lawyers are employees of Wells Fargo.
ADMITTED_______ DENIED________
45. Admit or Deny that in 2005 Wells Fargo told my rental property listing agent, Don Holman, that if there was a Purchase Agreement on my income property with a reasonably quick closing that Wells Fargo might delay the September 6, 2009, sale on the Courthouse steps of my home on Calle de Molina.
ADMITTED_______ DENIED________
46. Admit or Deny that Wells Fargo received a letter dated August 30, 2005, from my rental property listing agent, in which he identified himself as, “a licensed Real Estate Broker working for Coldwell Banker Trails West Realty, Ltd. in Santa Fe, New Mexico.”
ADMITTED_______ DENIED________
47. Admit or Deny that Wells Fargo received a letter dated August 30, 2005, from my rental property listing agent, Don Holman, who wrote saying that he had been told by Wells Fargo that if there was “a Purchase Agreement on my income property with a reasonably quick closing that Wells Fargo might delay the sale on the Courthouse steps enabling Ms. Kline to pay up her debt and retain her home on Calle de Molina.”
ADMITTED_______ DENIED________
48. Admit or Deny that Wells Fargo received a letter dated August 30, 2005, from my rental property listing agent, Don Holman, in which he wrote, “On August 24, 2005 I listed Karen’s rental property at 2836 Vereda de Pueblo, Santa Fe, NM. We were delighted to receive an exceptionally good offer the next day. The offer was for $212,000, which was $2100 above asking price, and called for a closing date of October 3, 2005. The Buyer has subsequently requested a change in the closing date to September 22, 2005.”
ADMITTED_______ DENIED________
49. Admit or Deny that Wells Fargo received the copy of the MLS printout which Don Holman sent with his August 30, 2005, letter to Wells Fargo for Wells Fargo’s review.
ADMITTED_______ DENIED________
50. Admit or Deny that Wells Fargo received the copy of the Purchase Agreement which Don Holman sent with his August 30, 2005, letter to Wells Fargo for Wells Fargo’s records.
ADMITTED_______ DENIED________
51. Admit or Deny that Wells Fargo received the copy of the “very strong loan commitment letter from the lender, a Mortgage Department of a local bank,” of which Holman wrote that it was “one of the strongest I have seen,” and which Don Holman sent with his August 30, 2005, letter to Wells Fargo for Wells Fargo’s records.
ADMITTED_______ DENIED________
52. Admit or Deny that Wells Fargo received an assurance from Don Holman in his August 30, 2005 letter to Wells Fargo that “the Purchase Agreement is exceptionally clean and contains no unusual contingencies.”
ADMITTED_______ DENIED________
53. Admit or Deny that Wells Fargo received assurance from Don Holman in his August 30, 2005 letter to Wells Fargo that “Karen’s payoff on the Vereda de Pueblo property is only about $67,000, which will provide ample funds for her to pay Wells Fargo.”
ADMITTED_______ DENIED________
54. Admit or Deny that Wells Fargo received contact information from Don Holman in his August 30, 2005 letter to Wells Fargo, “please feel free to call any of the phone numbers listed below my name. Or, if you prefer, you may contact me by email at donholman@sfar.com. You may also contact my Qualifying Broker, Chuck McKinley, at 505-983-0313 if you need verification of the above.”
ADMITTED_______ DENIED________
55. Admit or Deny that Wells Fargo contacted Don Holman to verify that Kline’s loan could be paid off on September 22, 2005.
ADMITTED_______ DENIED________
56. Admit or Deny that Wells Fargo contacted Chuck McKinley to verify that Kline’s loan could be paid off on September 22, 2005.
ADMITTED_______ DENIED________
57. Admit or Deny that after Wells Fargo received Don Holman’s letter of August 30, 2005, Wells Fargo did not stop trying to sell my home at foreclosure auction.
ADMITTED_______ DENIED________
58. Admit or Deny that Wells Fargo spoke in bad faith when it told Don Holman that if there was a Purchase Agreement on my income property with a reasonably quick closing that Wells Fargo might delay the September 6, 2009, sale on the Courthouse steps of my home on Calle de Molina.
ADMITTED_______ DENIED________
59. Admit or Deny that Wells Fargo received my letter of 9/1/05 in which I told Wells Fargo that I wanted to pay off my mortgage loan on 3255 Calle de Molina on 9/22/05.
ADMITTED_______ DENIED________
60. Admit or Deny that Wells Fargo received the email, included in my letter of 9/1/05, in which title company agent, Attarah Gutierrez, who was closing the sale of my rental on Vereda de Pueblo, wrote, “Yes,” she could pay off my mortgage loan on my home.
ADMITTED_______ DENIED________
61. Admit or Deny that Wells Fargo did not accept my 9/1/05 offer to pay off my home at 3255 Calle de Molina from the sale of my rental property on Vereda de Pueblo.
ADMITTED_______ DENIED________
62. Admit or Deny that Wells Fargo acted in bad faith when it did not accept my 9/1/05 offer to pay off the Wells Fargo mortgage on my home at 3255 Calle de Molina from the 9/22/05 sale of my rental property on Vereda de Pueblo.
ADMITTED_______ DENIED________
63. Admit or Deny that instead of accepting my offer to pay off my home at 3255 Calle de Molina on 9/22/05, Wells Fargo instructed its lawyers to continue trying to sell my home at foreclosure auction.
ADMITTED_______ DENIED________
64. Admit or Deny that it is Wells Fargo’s policy to reject homeowner’s offers to pay off their mortgages after Wells Fargo has collected mortgage insurance.
ADMITTED_______ DENIED________
65. Admit or Deny that foreclosures are a sham when Wells Fargo refuses to let homeowners pay off their mortgages and keep their homes.
ADMITTED_______ DENIED________
66. Admit or Deny that this foreclosure action on Karen Kline’s home at 3255 Calle de Molina should be dismissed with prejudice because of Wells Fargo refusing to accept Kline’s offer to pay off her Wells Fargo home mortgage on this home on 9/22/05.
ADMITTED_______ DENIED________
67. Admit or Deny that Wells Fargo acted in bad faith when it went on trying to sell Kline’s home at foreclosure auction rather than accepting Kline’s offer to pay off her home at 3255 Calle de Molina on 9/22/05.
ADMITTED_______ DENIED________
68. Admit or Deny that Wells Fargo acted in bad faith when it scheduled another foreclosure auction on Kline’s home for November 9, 2005 instead of accepting Kline’s offer to pay off her mortgage on 9/22/05.
ADMITTED_______ DENIED________
69. Admit or Deny that Don Holman’s affidavit of 8/30/05, filed in the foreclosure action, affirmed the contents of his August 30, 2005 letter to Wells Fargo, mentioned in above Affirmations.
ADMITTED_______ DENIED________
70. Admit or Deny that Wells Fargo has a policy regarding bankruptcies when evaluating a mortgage loan request.
ADMITTED_______ DENIED________
71. Admit or Deny that if Karen Kline had not filed bankruptcy in 2005, prior to the 9/6/05 auction of her home, Wells Fargo would have auctioned her home because Wells Fargo refused to accept Kline’s offer to pay off the mortgage on her home at 3255 Calle de Molina on 9/22/05.
ADMITTED_______ DENIED________
72. Admit or Deny that when Wells Fargo refused to accept Kline’s 9/1/05 offer to pay off her home mortgage on 9/22/05 Wells Fargo forced Kline to file bankruptcy to save her home from Wells Fargo’s auction of Kline’s home on 9/6/05.
ADMITTED_______ DENIED________
73. Admit or Deny that Wells Fargo’s home mortgage loan policy regarding bankruptcies would have prohibited Kline from refinancing her home in May, June, July, August, or early September 2007.
ADMITTED_______ DENIED________
74. Admit or Deny that Kline’s September 2005 bankruptcy restricted her access to her equity in her home for at least two years thereafter due to the policy of Wells Fargo regarding bankruptcies.
ADMITTED_______ DENIED________
75. Admit or Deny that generally banks have a policy regarding bankruptcies that is similar to that of Wells Fargo.
ADMITTED_______ DENIED________
76. Admit or Deny that by refusing to accept Kline’s 9/1/05 offer to pay off her mortgage Wells Fargo caused Kline to file bankruptcy to save her home and that in so doing Kline lost access to her equity by means of a refinance for at least two years.
ADMITTED_______ DENIED________
77. Admit of Deny that after the so called “Mortgage Meltdown” became widespread in late summer 2007 Kline’s access to her equity was made nil because of her September, 2005 bankruptcy.
ADMITTED_______ DENIED________
78. Admit or Deny that Wells Fargo would not accept the 9/21/05 dismissal of my bankruptcy and give me any money from the check I deposited after closing my rental property.
ADMITTED_______ DENIED________
79. Admit or Deny that Wells Fargo said it didn’t make any difference if I produced the Order dismissing my bankruptcy or not, it would not give me any money from my account because I had filed bankruptcy.
ADMITTED_______ DENIED________
80. Admit or Deny that Wells Fargo caused damage to my credit when Wells Fargo refused to accept my 9/1/05 offer to pay off my Wells Fargo home mortgage, thus forcing me to file bankruptcy to save my home from the Wells Fargo auction.
ADMITTED_______ DENIED________
81. Admit or Deny that Wells Fargo has caused the present foreclosure by its actions which have caused me to be unable to access the equity in my home at 3255 Calle de Molina.
ADMITTED_______ DENIED________
82. Admit of Deny that in fall 2007 my home’s equity was at least $150,000.
ADMITTED_______ DENIED________
83. Admit or Deny that when I could not refinance I lost my equity of $150,000.
ADMITTED_______ DENIED________
84. Admit or Deny that Wells Fargo will have caused me damages in the amount of $150,000 if my home is foreclosed and auctioned now when I have been unable to access my equity as a result of Wells Fargo refusing to accept my 9/1/05 offer to pay off my mortgage on 9/22/05.
ADMITTED_______ DENIED________
86. Admit or Deny that June 23, 2009 at 1:10 p.m. Wells Fargo told me and a Hope Now counselor that my loan modification request had been denied because of a $700+ deficit each month.
ADMITTED_______ DENIED________
87. Admit or Deny that Wells Fargo had not evaluated my loan modification request pursuant to the US Treasury March 4, 2009 guidelines for Home Affordable Modification Guidelines, see Admission 34 above, prior to denying my loan modification request on or about June 23, 2009.
ADMITTED_______ DENIED________
88. Admit or Deny that the verified budget I sent Wells Fargo, confirmed receipt shown in Admission 85 above, showed a surplus each month of $30 if loan modification according to the March 4, 2009 US Treasury guidelines was approved.
ADMITTED_______ DENIED________
89. Admit or Deny that on August 15, 2009 Rebecca of Wells Fargo Home Mortgage called and said that my loan modification had been denied because I didn’t earn enough money for Wells Fargo to use the 31% of income rule, pursuant to US Treasury Guidelines for Home Affordable Loan Modification, to establish a lower mortgage payment.
ADMITTED_______ DENIED________
90. Admit or Deny that the US Treasury Guidelines do not specify an income amount below which a home owner may not be granted Home Affordable Loan Modification.
ADMITTED_______ DENIED________
91. Admit or Deny that my on August 15, 2009 Rebecca of Wells Fargo Home Mortgage called and said that utility and food costs shown in my budget were far below national averages.
ADMITTED_______ DENIED________
92. Admit or Deny that on August 15, 2009 Rebecca of Wells Fargo Home Mortgage called and said that because my utility and food costs shown in my budget were far below national averages Wells Fargo raised those numbers.
ADMITTED_______ DENIED________
93. Admit or Deny that Wells Fargo falsified the numbers in my loan modification request when it changed them from true numbers submitted by me, explaining that I have solar and do not use Utility Company gas and electric, and that I have a garden out of which I eat, which reduces how much I have to pay for food, and additionally I get some meals from Kitchen Angels.
ADMITTED_______ DENIED________
94. Admit or Deny that Wells Fargo received my Hardship Letter faxed 5/21/09 to Wells Fargo among other times in which I explained about eating out of my garden.
ADMITTED_______ DENIED________
95. Admit or Deny that on May 21, 2009 Wells Fargo confirmed receipt of my Making Home Affordable Loan Modification Request to include Hardship Letter, budge, bank statements, Social Security Awards letters for which Wells Fargo confirmed fax receipt:
Time: 5/21/2009 2:31:19 PM
Sent to 8663597363 with remote ID “”
Result: (0/339;0/0) Successful Send
Page record: 1 – 17
Elapsed time: 13:56 on channel 13
ADMITTED_______ DENIED________
96. Confirm or Deny that after I paid my Escrow Deficit to Wells.
ADMITTED_______ DENIED________
97. Confirm or Deny that after I paid my Escrow Deficit I explained to Wells Fargo that my not donating to charity every month I would have enough to pay my escrow costs each month on top of my loan payment.
ADMITTED_______ DENIED________
Respectfully submitted,
Karen Marie Kline
Santa Fe, New Mexico 87507
***
FIRST JUDICIAL DISTRICT COURT
COUNTY OF SANTA FE
STATE OF NEW MEXICO
Wells Fargo Bank NA,
Plaintiff,
v. No. D-101-CV-200800942
Karen Marie Kline, Pueblos de Rodeo Road Owners
Association, Inc.; Manhattan Condominium Association,
Defendants.
CERTIFICATE OF SERVICE OF DEFENDANT KAREN MARIE
KLINE’S REQUESTS FOR ADMISSIONS TO PLAINTIFF
WELLS FARGO BANK NA
I hereby certify that on September 12, 2009, I sent two copies of my
Requests for Admission pursuant to Rule 1-036 NMRA to:
Sharon Hankla and D. Renae Richards Charney
Castle, Meinhold & Stawiarski
20 First Plaza NW Suite 602
Albuquerque, New Mexico 87102
Respectfully submitted,
Karen Marie Kline, Defendant, pro se
Santa Fe, New Mexico 87507
CERTIFICATE OF SERVICE: I caused a true copy of the above
CERTIFICATE OF SERVICE OF DEFENDANT KAREN MARIE
KLINE’S REQUESTS FOR ADMISSIONS TO PLAINTIFF WELLS
FARGO BANK NA to be mailed today, September 12, 2009, to:
Sharon Hankla and D. Renae Richards Charney
Castle, Meinhold & Stawiarski
20 First Plaza NW Suite 602
Albuquerque, New Mexico 87102
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