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8. whether Respondent searched archived, off-system, vendor, custodian, or predecessor records; and
9. whether any documents were destroyed, transferred, archived, withheld, or deemed unavailable.
VI. Specific Documents to Be Compelled
Movant requests an order compelling Respondent to produce the following documents and information for the loan, note, mortgage, collateral file, receivable, servicing rights, or proceeds at issue:
A. Operating Circular 10 Documents
1. Any Federal Reserve Operating Circular 10 agreement, lending agreement, promissory note, letter of agreement, authorizing resolution, board resolution, secretary’s certificate, or borrower authorization applicable to Respondent, its predecessor, its principal, or any entity that pledged the loan.
2. Any OC-10 appendix, rider, amendment, collateral authorization, borrower certification, or agreement authorizing the pledge of loans, mortgage notes, mortgage-loan receivables, or related collateral.
3. Any document identifying the institution authorized to borrow from or pledge collateral to a Federal Reserve Bank in relation to the loan or collateral pool containing the loan.
B. Collateral Schedule and Pledge Records
4. Any collateral schedule identifying the note, mortgage loan, receivable, collateral file, or related asset.
5. Any pledge record showing that the note, mortgage loan, receivable, or collateral file was pledged to a Federal Reserve Bank.
6. Any release, withdrawal, substitution, amendment, collateral-deletion, collateral-addition, or collateral-maintenance record.
7. Any Reserve Bank valuation, eligibility, review, exception, collateral-status, loan-level, pool-level, or haircut record.
8. Any record showing whether the note or loan was accepted, rejected, excluded, discounted, valued, substituted, released, withdrawn, or deemed ineligible as Federal Reserve collateral.
C. Borrower-in-Custody and Custodial Records
9. Any borrower-in-custody agreement applicable to the loan or collateral pool.
10. Any borrower-in-custody certification, eligibility certification, exception report, audit report, control report, or custody acknowledgment.
11. Any custodian, document-custodian, bailee, vault, imaging, file-tracking, or collateral-control record identifying the original note or collateral file.
12. Any record showing the location, controller, custodian, bailee, vault, file room, or repository of the original note at any time.
D. Original Note, Copies, and Digital Records
13. The original wet-ink note.
14. Every copy, scan, image, version, reproduction, or digital image of the note ever maintained, transmitted, filed, produced, or stored.
15. Metadata, upload logs, imaging logs, scan history, re-scan history, document-management history, custodian-system history, and version history for each note image.
16. Any document showing that the original note was digitized, converted, destroyed, lost, released, transferred, substituted, or replaced.
17. Any eNote, eVault, MERS eRegistry, controller, location, authoritative-copy, transfer, conversion, or electronic-record history for the note, if Respondent contends the note became electronic or digitized for enforcement purposes.
E. Accounting and General Ledger Records
18. All general-ledger entries relating to the note, mortgage loan, receivable, collateral file, servicing rights, collateral proceeds, sale proceeds, insurance proceeds, investor remittances, repurchase proceeds, guaranty proceeds, foreclosure proceeds, bankruptcy payments, or other value received.
19. All records showing whether value received in connection with the loan was booked as a payment, deposit, loan payoff, principal reduction, interest payment, escrow recovery, suspense item, corporate-advance recovery, servicing or investor remittance, loan-sale proceeds, collateral-pledge proceeds, reserve-account credit, clearing-account credit, cash-letter credit, insurance recovery, repurchase proceeds,derecognition or charge off.