DEFENDANT LVNV 

FUNDING, LLC’s RULE 

26(a)(1) DISCLOSURES 

0605-03 ss -1- 

STEPHEN A. BERNHEIM 

ATTORNEY AT LAW 

512 Bell Street 

Edmonds, Washington 98020 

(425) 712-8318 

Fax (425) 712-8418 

e-mail:steve@stevebernheim.com

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Honorable Ricardo S. Martinez 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

AT SEATTLE 

TANA IHRIG and MARK IHRIG, 

 Plaintiffs, 

 v. 

WASHINGTON MUTUAL BANK, et al., 

 Defendants. 

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NO. 2:06-cv-00512-RSM 

DEFENDANT LVNV FUNDING, 

LLC’s RULE 26(a)(1) DISCLOSURES 

Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, Defendant LVNV 

Funding, LLC (“LVNV”) provides the following information:

A. IDENTITY OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE 

INFORMATION RELEVANT TO DISPUTED FACTS. 

 Defendant LVNV identifies the following individual(s), other than Plaintiffs and the 

other named Defendants, who may have relevant information: John Shinovich, Authorized 

Representative, LVNV. 

Identification of any person does not constitute a representation that such person has 

information that is nonprivileged, nor does it constitute a waiver of any privilege or objection 

that may be made to such witness’s testimony. 

Case 2:06-cv-00512-RSM Document 35 Filed 07/26/06 Page 1 of 2
DEFENDANT LVNV 

FUNDING, LLC’s RULE 

26(a)(1) DISCLOSURES 

0605-03 ss -2- 

STEPHEN A. BERNHEIM 

ATTORNEY AT LAW 

512 Bell Street 

Edmonds, Washington 98020 

(425) 712-8318 

Fax (425) 712-8418 

e-mail:steve@stevebernheim.com

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 Defendant LVNV may identify additional witnesses through discovery and continued 

investigation. Defendant LVNV specifically reserves the right to offer witnesses at trial that 

are not identified above. 

B. DESCRIPTION (BY CATEGORY) OF ALL DOCUMENTS, DATA 

COMPILATIONS AND TANGIBLE THINGS THAT MAY BE RELEVANT 

TO DISPUTED FACTS. 

 Defendant LVNV identifies the following categories of documents, data compilations 

and tangible things that may be relevant to disputed facts: (i) notes of Defendant Resurgent 

Capital Services, LP, received after Plaintiffs filed this action; (ii) notes of the agencies with 

whom Plaintiffs’ account was placed, received after Plaintiffs filed this action. 

Defendant LVNV anticipates that Plaintiffs and the other named Defendants may also 

have documents, records, data and things that may be relevant to disputed facts. 

Defendant LVNV may identify additional categories of documents, data 

compilations, and other tangible things through discovery and continued investigation. 

Defendant LVNV specifically reserves the right to offer exhibits at trial that do not fall 

within the above-listed category. 

C. COMPUTATION OF DAMAGES CLAIMED BY DEFENDANT. 

 Not applicable. 

D. INSURANCE AGREEMENTS WHICH MAY BE LIABLE TO SATISFY 

PART OR ALL OF A JUDGMENT. 

Defendant LVNV has not tendered the defense of this claim to its insurance provider. 

DATED this 26th day of July, 2006 

/s/ Stephen A. Bernheim_______________ 

Stephen A. Bernheim, WSBA #15225 

Attorney for Defendants LVNV Funding, LLC, 

Resurgent Capital Services, LP and Sherman 

Financial Group LLC 

Case 2:06-cv-00512-RSM Document 35 Filed 07/26/06 Page 2 of 2