Técnicas e instrumentos de recolección de datos

l. All contracts between any plaintiff and any defendant including notes, judgment notes, security agreements, mortgages, and insurance agreements related to any transaction.

2. All disclosure statements or other notices given to any plaintiff related to any transaction.

3. All documents provided to any plaintiff describing the terms of any transaction.

4. All notices of right to cancel given to any plaintiff in connection with any transaction.

5. The loan application, loan worksheet, application worksheet or other document used in considering the application of any plaintiff for a loan.

6. The settlement statement, commitment letter and any worksheet or other document used to prepare the federal disclosure statement in any transaction.

7. All letters, notices and forms relating to defendants' intention to foreclose on any subject property.

8. All ledger cards, ledger sheets or other documents reflecting payments made, and charges and costs incurred in any transaction.

9. All written communications either by or to any plaintiff.

10. All telephone log sheets, internal memoranda, notes or other documents concerning any transaction prepared or reflecting activity on any plaintiff's account.

11. All documents recording, reflecting or otherwise relating to visits which any plaintiff or anyone acting on their behalf made to your office in connection with any transaction.

12. All documents you rely on for assessing attorneys fees and costs on the plaintiffs in this matter, including but not limited to fee agreements, contracts, bills, timesheets, attorney work records, canceled checks and other documents supporting fees assessed for an attorney in connection with closing any transaction.

13. All documents defendants rely on for payment of document preparation fees in any transaction.

14. All documents defendants rely on for payments made to any entity, including any plaintiff, in connection with any transaction including, but not limited to, contracts, bills, canceled checks and other back-up documentation for such payment.

15. All documents relating to any fees, commissions or other payment to any third party in connection with any transaction whether or not such payment was charged to any plaintiff.

16. All documents relating to any fees, commissions or payments received by any defendant in connection with any transaction from anyone other than a plaintiff.

17. All contracts, agreements, correspondence, records of communication or other documents reflecting interaction with any loan broker who was paid in any transaction.

18. All documents your employees or agents had received from you or any third party at the time of any transaction concerning the requirements of the federal Truth-in-Lending Act or the state Consumer Credit Cost Disclosure Act.

19. All documents relating to any internal inspection procedures you used at the time of any transaction to insure that your employees or agents were complying with the Truth-in-Lending Act and the state Consumer Credit Cost Disclosure Act.

20. A copy of the outside and inside front and back of the file folder on any of plaintiff's loan accounts.

21. Copies of both sides of each and every check issued or received in connection with any transaction.

22. All documents reflecting commissions and/or bonuses paid to any individual including, but not limited to, payments to your employees, agents and any loan broker in connection with any transaction.

23. All contracts, agreements, correspondence, records of telephone conversations, memoranda or other documents reflecting communication between you and any other defendant involved in this matter related to any transaction, subject property or plaintiff in this case.

24. All contracts, agreements, correspondence, records of telephone conversations,

memoranda and other documents reflecting communication between you and any person or entity who loaned money to any plaintiff whether or not such person or entity is a defendant in this case.

25. All documents related in any way to any criteria or system used to determine any plaintiff's credit worthiness.

26. All documents used in choosing, determining, setting, changing or adjusting the interest rate in any transaction, including any documents related to how the amount of the interest rate relates to any plaintiff's individual circumstances.

27. All documents related in any way to any terms required as a condition for entering into a loan agreement with any plaintiff.

28. All of the above enumerated documents with respect to any previous or subsequent transaction with any plaintiff.

29. All documents from whatever source relating in any way to the fair market value of any subject property.

30. All advertisements sent to any plaintiff by mail and the transcript of any telephone advertisements or other solicitation made directly to any plaintiff at any time.

31. The text of any published advertisement you used in any print or electronic media between January 1, 1988 and December 31, 1992.

32. The results of all title and lien searches of any subject property.

33. All documents related to establishment, maintenance, collection or disbursement of an escrow in any transaction.

34. All mortgages, security agreements or other documents reflecting security interests held by third parties such as your creditors in any mortgage and/or note executed by any plaintiff in any transaction.

35. All corporate records maintained by you which reflect:

a. the identity of your corporate officers, executives or shareholders for any period of time since the corporation was formed;

b. any financial relationship between your corporation and any other corporation, individual or other entity; and

c. any agreements, financial relationship or any other connection between your corporation and any other defendant in this lawsuit.

36. All contracts, agreements, memoranda of understanding or any other document reflecting an agreement between you and any other defendant whether or not such agreement relates to this case.

37. All bank records of any accounts held by you at any time since January 1, 1989.

38. Any and all documents which you intend to use or introduce at trial.

Dated:

7.3 Motion for Remand

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Mary Glass, Brenda Old, and Donna Smith