IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA MIDLAND FUNDING LLC as successor in interest to Bank of America

Plaintiff, Vs. XXXXXXXX Defendant(s) ______________________________/ CASE NO. COWE 11-XXX CIVIL ACTION SUMMONS

RESPONSE TO PLAINTIFFS REQUEST TO PRODUCTION OF DOCUMENTS EXHIBIT D Comes now, Defendant XXXXXXX pro se, and files respond to Plaintiffs Request for Production of Documents, as set forth in the following manner:

GENERAL OBJECTIONS

Defendant generally objects and responds to the Document Request on the grounds set forth below. All general objections shall be deemed to be continuing and shall be construed as supplementing each specific objection and/or response to the Document Requests. A. Defendant objects generally to the Document Request is not intended and should not be construed to the extent they assume facts that are inaccurate, argumentative and defective in form. B. Defendant objects generally to the Document Request to the extent they seek documents not in its possession, custody or control.

1. Defendant objects as the Plaintiffs request for Documents No. 1 as it assumes there is an account being sued upon where no valid account has been identified yet by the Plaintiff. The defendant cannot provide what is requested. 2. See Attached.

3. Defendant objects as the Plaintiffs request for Documents No. 3 is overbroad and unduly burdensome to the extent it seeks document or records that are not within the current knowledge, possession, custody or control of the Defendant. The Plaintiff claims they are the Assignee of the alleged account therefore these documents should be more readily or accessible to Plaintiff from its own files, from documents already in Plaintiffs possession. The defendant has no documents to provide this request. 4. Defendant objects as the Plaintiffs request for Documents No. 4 on the grounds that it is burdensome, seeing it is requesting documents in regard to the contract sued upon, where no contract as of yet has been identified by the Plaintiff or their attorneys. The Defendant has nothing is his possession to provide.

5. Defendant objects the extent that it requires defendant to respond by supplying information is already in the possession of or equally available to Plaintiff. Defendant is still in the process of gathering evidence for trial and will provide Plaintiff with information responsive to this request as soon as it becomes available. 6. Defendant objects the extent that it requires defendant to respond by supplying information is already in the possession of or equally available to Plaintiff. Defendant is still in the process of gathering evidence for trial and will provide Plaintiff with information responsive to this request as soon as it becomes available.

7. Defendant objects the extent that it requires defendant to respond by supplying information is already in the possession of or equally available to Plaintiff. Defendant is still in the process of gathering evidence for trial and will provide

Plaintiff with information responsive to this request as soon as it becomes available. 8. Defendant objects the extent that it requires defendant to respond by supplying information is already in the possession of or equally available to Plaintiff. Defendant is still in the process of gathering evidence for trial and will provide Plaintiff with information responsive to this request as soon as it becomes available.

9. See attached Exhibit B, C. 10. See attached Exhibit B, C .

11. See attached Exhibit B, C. 12. Defendant objects as the Plaintiffs request for Documents No. 12 as it assumes there is an account being sued upon where no valid account has been identified yet by the Plaintiff. The defendant cannot provide what is requested.

13. Defendant objects as the Plaintiffs request for Documents No. 13 as it assumes there is an account being sued upon where no valid account has been identified yet by the Plaintiff. The defendant cannot provide what is requested. 14. Defendant objects as the Plaintiffs request for Documents No. 14 as it assumes there is an account being sued upon where no valid account has been identified yet by the Plaintiff. The defendant cannot provide what is requested.

Defendant, ____________________________ XXXXXXXXX XXXXXXXX