Requests for Admissions

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, you should 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, itself, 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.

.

.


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 and
likewise 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 Marie
Kline.

 

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 possession
of 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 published
March 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 Kline
sent 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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