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Request for Admissions

This is a request for admissions sent by a Florida homeowner to the reverse mortgage lender seeking the lender’s admission that the home was in fact occupied, despite the lender taking actions as if the home was unoccupied.

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This is a consumer’s motion directed to a mortgage servicer asking the court to deem the consumer’s requests for admission admitted. A separate Pleading and Discovery file is a reply to the servicer’s objection, and a proposed order. These documents address frivolous objections commonly raised by corporate defendants including: the document speaks for itself, the facts are public record and may be easily verified by the requestor, and the request seeks admission of a legal theory rather than a fact. Although filed in state court (Maine) it applies the Fed. R. Civ. P.

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