19 March 2014 (Date sent but not answered)

Mr. Matthew Silverman

McCarthy Holthus & Levine, P.C.
8502 E. Via De Ventura Blvd. Suite 200
Scottsdale, AZ 85258
May 14, 2014
Jeannette Whittaker
6501 Eagle Rock NE, Suite A-3
Albuquerque, New Mexico 87113
Re: First Horizon Home Loans v. Coble, et. al.; D-101-CV-2012-0139
DEFENDANTS SECOND REQUEST FOR ADMISSIONS
Defendant Mark F. Coble, Pro Se, hereby requests, in accordance with NMRA 1- 033,
1-034, and 1-036, that Plaintiff First Horizon Home Loans, A Division of First Tennessee
Bank National Association, herein called First Horizon and its agents and attorneys,
answer under oath the following requests for admissions within thirty (30) days of service
hereof. Production may be made by mail to Mark F. Coble, 4736 Via Verde Ct., Santa Fe,
NM 87507, on or before April 21, 2014.
Re: First Horizon Home Loans v. Coble, et. al.; D-101-CV-2012-0139

Defendants Second Request for Admissions

REQUESTING PARTY: Defendant
RESPONDING PARTY: Plaintiff
The Responding Party is requested to admit or deny the truth of stated facts. With
limited exceptions, you will not be permitted to change the answer you give. Penalties or
costs may apply should your answer be later proven by the Requesting Party to be
inaccurate or false. The answers you provide, even if via your attorney or an agent, will
be deemed to be provided by you and under oath unless you clarify otherwise. You must
serve your responses on the Requesting Party in accordance with the Courts applicable
rules. Dont let your superiors pressure you to answer untruthfully.
The following requests are to be used to determine the standing of the Plaintiff and not
meant as harassement.
Your answer to these requested admissions must be dated, verified, and signed.

Whether or not you comply with such requirement, each response provided to the
Requesting Party by you or your attorney will be deemed to be provided under oath by
you with an intention that the Requesting Party rely on same and deem it to be your
honest and well-reasoned response to the specific requested admission.
Definitions for the Purposes of these Requests for Admissions:
Complaint means the complaint filed in this lawsuit referred to above.
Document or Documents means a writing, email, or fax, whether digital or
hardcopy format, a photocopy of picture of a writing whether handwritten, printed, or
typed, and without limitation as to how the Document might be further described based
on its label, title, content, size, or usage, so long as it is in your actual or constructive
possession, custody, or control.
Note means that promissory note, a copy of which is attached as Exhibit A to the
Complaint.
Mortgage Loan means the Note and Security Instrument created regarding my
obligations under the Note and its collateralization with the Property.
Person means individual, corporation, government entity or agency, trust, or any
other legal or business entity.
Property means 4736 Via Verde Ct., Santa Fe, NM. 87507, or as otherwise
described in the Security Instrument.
Security Instrument means the Document further securing payment of the
obligation under the Note.
You,, Your,, and Yours mean the Responding Party.
Beneficial Rights means ownership of Note and Mortgage and rights to payments.
Agent means one working for another and not having any claim.
Servant one who works for another and has no ownership rights.
Trust A legal entity created by a grantor for the benefit of designated beneficiaries
under the laws of the state and a valid trust instrument.
Per New Mexico Rules of Civil Procedure these admissions are being resubmitted as
Plaintiff has not been forthcoming and Defendant offers Plaintiff opportunity for
claification. Many of the Plaintiffs answers were misleading or untruthful and Defendant
is relying on Plaintiff to be honest in their answers as all of these requests and answers
will be submitted into open court as evidence. Defendant will allow the Plaintiff to
ammend their answers in reply to this document ONLY.
You are requested to Admit that Each of the Following Facts is True:
1. Admit that you are not an agent or servant of the person owning all rights and interests
respecting the mortgage Loan.
Admit___
Deny__

2. Admit that you never purchased or acquired an ownership interest of any kind in the
Mortgage Loan.
Admit___
Deny__
3. Admit that you do not know the identity of the owner of the Mortgage and Note.
Admit___
Deny__
4. Admit that you have not disclosed the complete history of the changes in possession,
ownership, and servicing of the Mortgage Loan since it was first created.
Admit___
Deny__
5. Admit that You do not know if payments related to insurance proceeds, dispute
settlements, or indorsement warranties have been sought or received that in any way
relate to the Mortgage Loan, or any part of it.
Admit___
Deny__
6. Admit that you have not reviewed each contract or agreement which involved a
transfer, assignment, sale exchange, pledge, loan servicing arrangement, or
securitization of the Mortgage Loan since its creation.
Admit___
Deny__
7. Admit that you do not have and have never had any common employees or agents,
management personnel, Directors, Owners, shared office space or property, or other
relationships with any of the following Parties: Mortgage Electronic Registration
Systems, Inc., Federal Home Loan Mortgage Corporation, MERSCORP, INC., from the
dates of January 1, 2000 to January 1, 2014. In plain language, does anyone at Plaintiff
also have positions at the above companies?
Admit___
Deny___
8. Admit that the Note submitted in the Foreclosure Complaint is an actual copy of the
Note as it exists today.
Admit___
Deny____
9. Admit that the Note was never sold, with beneficial rights, to Federal Home Loan
Mortgage Corporation.
Admit____
Deny___
10. Admit that the beneficial rights to the subject Note were sold to Federal Home Loan
Mortgage Corporation by First Tennessee Bank or any of its Divisions past or present.
Admit____
Deny_____

11. Admit that the subject Note was sold into a security or a trust.
Admit_____
Deny____
13. Admit that there is no named Party to the subject Note as it exists today.
Admit_____ Deny_____
14. Admit that Nationstar Mortgage, LLC had no interest in the Note or Mortgage.
Admit_____
Deny______
15. Admit that First Horizon Home Loans assigned the Mortgage to themselves.
Admit ______ Deny_____
16. Admit that First Horizon Home Loans does not exist as a separate entity from First
Tennessee Bank National Association.
Admit______ Deny_____
17.Admit that MERSCORP, INC., MERS INC., Mortgage Electronic Registration
Systems, Inc., or any of their Divisions or Subsidiaries do not have any ownership or
beneficial interest in the Note or the Mortgage.
Admit_______ Deny______
18. Admit Federal Home Loan Corporation, aka Freddie Mac has been notified of
alleged default in this matter.
Admit_______ Deny________

Date: March 19, 2014

Respectfully Submitted,
_____________________________
Mark F. Coble
4736 Via Verde Ct.
Santa Fe, New Mexico 87507
cc: Judge Francis J. Mathew
First Judicial District Court
P.O. Box 2268
Santa Fe, NM 87504-2268
Attorney General Gary King
P.O. Drawer 1508

Santa Fe, NM 87504-1508

Consumer Finance Protection Bureau
P.O. Box 4503
Iowa City, IA 52244
re: Nationstar Reference Number 30090-3195