Attorneys for Jason Doe

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO CENTRAL DIVISION NATIONAL COLLEGIATE STUDENT CASE NO. LOAN TRUST 2004-1, A DELAWARE STATUTORY TRUST; LIMITED CIVIL CASE , DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION AND vs.

JASON DOE, and DOES 1 to 15; filed on: Defendant.

DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS PROPOUNDING PARTY: Jason Doe RESPONDING PARTY: National Collegiate Student Loan Trust 2004-1 SET NUMBER: One

Demand is hereby made by Defendant Jason Doe (“Defendant”) pursuant to California Code of sections 94 and 2031.010, et al., to Plaintiff National Collegiate Student Loan Trust 2004-1 (“Plaintiff”) to under oath the following First Set of Requests for Production and Inspection of Documents within 30 days as required by California Code of Civil Procedure section 2031.260.

The documents requested shall be produced on or before April 2, 2012. This request can be satisfied by mailing copies of the documents herein requested, and/or by presenting the originals, for a sufficient length of time to allow reasonable inspection, review, and photocopying, to the offices of the Legal Aid Society of San Diego, Inc., located at 110 South Euclid Avenue, San Diego, California 92114, Attn: Alysson Snow or Joe Villasenor, at any time on or before the date set for the production. The time for the inspection will be 9:00 a.m. on April 2, 2012. Please include a declaration, under penalty of perjury, that the documents being provided constitute all of the documents presently in existence and known to you to qualify for production under this notice. Failure to respond within the time allotted shall be deemed a waiver of any objections to the production of the documents requested herein and may subject the party refusing the request to an order to compel production. DEFINITIONS AND INSTRUCTIONS These written requests are being propounded pursuant to the provisions of the California Code of Civil Procedure sections 94 and 2031.010, et seq. These requests seek documents and things in the possession, custody, or control of responding party, or responding party’s attorneys or agents. Further, these requests seek documents and things that are relevant to the subject matter of this action or reasonably calculated to lead to the of admissible evidence in this action.

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DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS The following specially defined terms shall be utilized in this set of requests: A. “PLAINTIFF” or “YOU” or “YOUR” shall mean National Collegiate Student Loan Trust 2004-1 and its agents, employees, consultants, representatives, successors, predecessors in interest, and all other persons at any time acting or purporting to act for or on behalf of National Collegiate Student Loan Trust 2004-1 or its assignors or assignees. B. “DEFENDANT” shall mean Jason Doe. C. “PLAINTIFF’S ASSIGNOR” shall mean Plaintiff National Collegiate Student Loan Trust 2004-1’s alleged assignor and its agents, employees, consultants, representatives, and all other persons at any time acting or purporting to act for or on behalf of the alleged assignor. D. “ALL DOCUMENTS” or “DOCUMENT” or any variation thereof is used in its broadest sense and shall mean any writing, notes, drawing, graph, chart, photograph, tape, record, magnetic disc, computer disc, computer simulation, or any other data compilation from which information can be obtained, translated, if necessary through devices, and to a reasonably useable form, and including, but not limited to, correspondence, electronic mail, telegrams, cables, telex messages, telecopies, memoranda, notes, drafts, notations, work papers, transcripts, minutes, reports, recordings of telephone or other conversations or of interviews, conferences, or other meetings, affidavits, statements, journals, statistical records, desk calendars, appointment books, diaries, lists, tabulations, computer printouts, or any other items of a similar nature, including all originals, drafts, and non-identical copies. E. “RELATE” or “RELATING TO” means referencing, constituting, defining, evidencing, containing, comprising, embodying, reflecting, identifying, stating, referring to, dealing with, or in any way pertaining to. F. “EVIDENCE” shall be defined as set forth in Evidence Code section 140 as testimony, writings, material objects, or other things presented to the senses that are offered to prove the existence or nonexistence of a fact.

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DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS G. “PERSON” shall be defined by Evidence Code section 175 and mean a natural person, firm, association, organization, partnership, business trust, corporation, limited liability company, or public entity. H. “WRITING” shall be defined by Evidence Code section 250 and shall mean handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by electronic mail or facsimile, and every other means of recording upon any tangible thing, and form of communication or representation, including letters, words, pictures, sounds, or symbols, or combinations thereof, and any record thereby created, regardless of the manner in which the record has been stored. I. “COMPLAINT” shall be the Complaint filed by the Plaintiff National Collegiate Student Loan Trust 2004-1 on or around ***********. J. “LOAN” shall mean the student loan contract or note allegedly entered into between Plaintiff and Defendant on or around March 9, 2004. K. “SECURITIZATION” shall mean the offering of the LOAN to YOU from the loan originator or by YOU to any party as part of an effort to use DEFENDANT’s alleged obligation to pay as collateral for the creation of a security to be bought or sold. L. The singular shall include the plural and vice versa, and the conjunctive shall include the disjunctive and vice versa, to give these requests their broadest scope. The use of the word “including” shall be construed without limitation. M. If you claim attorney-client privilege and/or attorney work product privilege is applicable to any document, the production of which is sought by this request, with respect to each document, please: 1. State the date of the document; 2. Identify each and every author of the document; 3. Identify each and every person who prepared, or participated in the preparation of the document; 4. Identify each and every person who received the document;

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DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS 5. State the present location of the document; 6. Provide sufficient other information concerning the document to explain the claim of privilege and to adjudicate the propriety of the claim. N. Unless otherwise specifically noted, all requests are for the time period from March 09, 2002 to the present. DOCUMENT REQUESTS Request for Production No. 1: ALL DOCUMENTS RELATING TO the YOU are claiming in this action. Request for Production No. 2: ALL DOCUMENTS supporting YOUR calculation of YOUR alleged damages in this action. Request for Production No. 3: ALL DOCUMENTS reviewed to create YOUR alleged damages in this action. Request for Production No. 4: ALL DOCUMENTS RELATING TO YOUR alleged ownership of the claim in this action including the chain of title for the LOAN. Request for Production No. 5: All DOCUMENTS evidencing the alleged assignment of the contract to YOU. Request for Production No. 6: ALL DOCUMENTS showing YOUR demand on DEFENDANT for the amounts alleged as a debt in the COMPLAINT. Request for Production No. 7: ALL DOCUMENTS evidencing the account stated in writing as alleged in paragraph CC-1 subsection (b) of the COMPLAINT. Request for Production No. 8: ALL DOCUMENTS evidencing that DEFENDANT was indebted to YOU as alleged in the COMPLAINT. Request for Production No. 9: All DOCUMENTS evidencing payment by DEFENDANT to PLAINTIFF, if any, preceding the filing of this action. Request for Production No. 10: ALL DOCUMENTS containing any and all terms and conditions of the LOAN referenced in YOUR COMPLAINT.

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DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS Request for Production No. 11: The federal Truth in Lending Act disclosure statement for the LOAN referenced in YOUR COMPLAINT. Request for Production No. 12: A copy of the endorsed check which disbursed the proceeds of the LOAN. Request for Production No. 13: A signed acknowledgment, if any, that DEFENDANT received the disclosure statement and agreed to the terms of the LOAN. Request for Production No. 14: Any and all EVIDENCE showing the alleged money was disbursed pursuant to the LOAN. Request for Production No. 15: ALL DOCUMENTS RELATING TO the SECURITIZATION of the LOAN. Request for Production No. 16: ALL DOCUMENTS evidencing a written contract between DEFENDANT and PLAINTIFF’S ALLEGED ASSIGNOR as alleged in paragraph BC- 1 of the COMPLAINT. Request for Production No. 17: IDENTIFY ALL DOCUMENTS RELATED TO the alleged default by DEFENDANT on the LOAN. Request for Production No. 18: The original written contract, if any, between PLAINTIFF’S ALLEGED ASSIGNOR and DEFENDANT as alleged in paragraph BC-1 of YOUR COMPLAINT. Request for Production No. 19: A copy of the LOAN origination and sale agreement. Request for Production No. 20: A copy of the LOAN application Request for Production No. 21: A copy of the entire forward flow agreement RELATED TO DEFENDANT’s LOAN, including any and all attachments, exhibits, or referenced materials.

Dated: ********** By Attorneys for Defendant

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DEFENDANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS