SUPERIOR COURT OF THE STATE OF CALIFORNIA

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1 1 1 ARNOLD & PORTER LLP Ronald L. Johnston (State Bar No. 0) Eric D. Mason (State Bar No. ) Ryan O. McMonagle (State Bar No. ) South Figueroa Street, th Floor Los Angeles, California 00- Telephone: () -000 Facsimile: () - Ronald.Johnston@aporter.com Eric.Mason@aporter.com Ryan.McMonagle@aporter.com LAWYERS COMMITTEE FOR CIVIL RIGHTS UNDER LAW Linda Mullenbach (pro hac vice admission pending) Meredith Horton (pro hac vice admission pending) 01 New York Avenue, NW, Suite 00 Washington, DC 00 Telephone: () -00 Facsimile: () -0 LMullenbach@lawyerscommittee.org MHorton@lawyerscommittee.org Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES MARCIA BAKER, an individual; et al., Case No.: BC0 v. Plaintiffs, PLATINUM LAW GROUP, INC., a corporation; et al., Defendants. PLAINTIFFS FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS TO DEFENDANT JERRY STEVENSON Assigned for all purposes to: Judicial Officer: Hon. Barbara Scheper Department: 0 0v1

2 Propounding Party: Set Number: Responding Party: Plaintiffs One Defendant Jerry Stevenson Pursuant to California Code of Civil Procedure 1.0 et seq., Plaintiffs Marcia Baker, Denise Burns, Juanita Craig, Michael Craig, Julia Cringle, Carol Frost, Dwight Reep, and Roberto Velasquez (collectively, Plaintiffs ) request that Defendant Jerry Stevenson ( Stevenson ) produce the documents and things described below for inspection and copying on July, 1 at :00 a.m., at the offices of Arnold & Porter LLP, South Figueroa Street, th Floor, Los Angeles, California, 00. DEFINITIONS ADDRESS means the street address, including the city, state, and zip code.. COMMUNICATION means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise) including, without limitation, meetings, conferences, seminars, discussions, conversations, telephone calls, recordings, photographs, notes, memoranda, letters, facsimiles, telexes, electronic mail, or electronic media.. DEFENDANTS means Platinum Law Group, Inc.; Modern Media Services, Inc.; Platinum Law Center, A Professional Corporation; HLM Consulting, Inc.; Priority Realty Group, Inc.; Priority Financial Group; Priority Mortgage Group, Inc.; LaBrea Group LLC; Baldwin Property Partners LLC; Diana Ambriz; Daniel Ardon; John de la Garza; David Gomez; Raudel Guerrero; Paul Hernandez; Jay Jackson; Jeff Marklein; Charlie Melendez; Michael Morga; John Romero; Jerry Stevenson; Martha Tapia; and DOES 1-; the defendants named in the Complaint filed on May 1, 1.. DOCUMENT means a writing, as defined in Evidence Code section 0, and includes the original or copy of handwriting, typewriting, printing, photostats, photographs, electronically stored information, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them

3 1 1. IDENTIFY means to state the following: (1) when used with respect to a PERSON, the name of the PERSON, the ADDRESS of the PERSON, and the PERSON s other identifying information, such as title and affiliation to any other PERSON; and () when used with respect to a DOCUMENT, information describing the DOCUMENT with sufficient particularity so as to allow that DOCUMENT to be the subject of a request for production, including, but not limited to, title, author, recipient(s), and date the DOCUMENT was created.. LENDER means each and every mortgage lender, servicer, or other entity with respect to which LOAN MODIFICATION SERVICES were contemplated or provided for each of the PLAINTIFFS.. LOAN MODIFICATION SERVICES means any and all services that YOU and/or YOUR representatives, agents, contractors, and/or employees performed for or on behalf of, or offered or agreed to perform for or on behalf of any PERSON, including representing such PERSONS with respect to their loan modifications, and negotiating with those PERSONS respective LENDERS to modify their current loans.. PERSON means as so defined in Evidence Code section and includes a natural person, firm, association, organization, partnership, business, trust, limited liability company, corporation, or public entity.. PLAINTIFFS mean Marcia Baker, Denise Burns, Juanita Craig, Michael Craig, Julia Cringle, Carol Frost, Dwight Reep, and Roberto Velasquez -- the plaintiffs named in the Complaint filed on May 1, 1. YOU and YOUR refer to Defendant Jerry Stevenson, and his agents, attorneys, and any other PERSON acting for or on his behalf. DOCUMENT REQUEST NO. 1 REQUESTS FOR PRODUCTION DOCUMENTS sufficient to IDENTIFY the name, ADDRESS, telephone number, and principal place of business of each of the DEFENDANTS. - -

4 1 1 DOCUMENT REQUEST NO. DOCUMENTS sufficient to IDENTIFY all owners, officers, directors, and PERSONS with any legal or beneficial ownership interest in any of the DEFENDANTS. DOCUMENT REQUEST NO. DOCUMENTS sufficient to IDENTIFY all PERSONS affiliated with, employed by, contracted by, controlled by, or acting on behalf of YOU that provided, offered to provide, or agreed to provide LOAN MODIFICATION SERVICES to any PLAINTIFF or other member of the public. DOCUMENT REQUEST NO. All DOCUMENTS containing or relating to any statements, representations, or other COMMUNICATIONS made by DEFENDANTS to any of the PLAINTIFFS. DOCUMENT REQUEST NO. All DOCUMENTS relating to YOUR practice of charging upfront fees for LOAN MODIFICATION SERVICES. DOCUMENT REQUEST NO. All DOCUMENTS sent by YOU to PLAINTIFFS respective LENDERS, received by YOU from PLAINTIFFS LENDERS, or that otherwise mention PLAINTIFFS LENDERS. DOCUMENT REQUEST NO. All DOCUMENTS mentioning PLAINTIFFS. DOCUMENT REQUEST NO. All of YOUR employee manuals, customer service manuals, or similar employee training and procedure manuals. - -

5 DOCUMENT REQUEST NO. All of YOUR organizational charts. DOCUMENT REQUEST NO. All of YOUR advertising, whether in printed, electronic, television, radio, or other format, that relates to LOAN MODIFICATION SERVICES. DOCUMENT REQUEST NO. All DOCUMENTS you IDENTIFY or rely upon in responding to PLAINTIFFS Special Interrogatories (Set One) or PLAINTIFFS Form Interrogatories (Set One), served concurrently herewith. 1 1 Dated: May, 1 Respectfully submitted, By: Ronald L. Johnston Eric D. Mason Ryan O. McMonagle ARNOLD & PORTER LLP Linda Mullenbach Meredith Horton LAWYERS COMMITTEE FOR CIVIL RIGHTS UNDER LAW Attorneys for Plaintiffs MARCIA BAKER, DENISE BURNS, JUANITA CRAIG, MICHAEL CRAIG, JULIA CRINGLE, CAROL FROST, DWIGHT REEP, and ROBERTO VELASQUEZ - -