DEFENDANT SHERMAN 

FINANCIAL GROUP, 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 SHERMAN 

FINANCIAL GROUP, LLC’s RULE 

26(a)(1) DISCLOSURES 

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

Sherman Financial Group, LLC (“Sherman Financial”) provides the following information:

A. IDENTITY OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE 

INFORMATION RELEVANT TO DISPUTED FACTS. 

 Defendant Sherman Financial identifies the following individual(s), other than 

Plaintiffs and the other named Defendants, who may have relevant information: John 

Shinovich, Authorized Representative, Sherman Financial. 

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. 

 Defendant Sherman Financial may identify additional witnesses through discovery 

and continued investigation. Defendant Sherman Financial specifically reserves the right to 

offer witnesses at trial that are not identified above. 

Case 2:06-cv-00512-RSM Document 34 Filed 07/26/06 Page 1 of 2
DEFENDANT SHERMAN 

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

COMPILATIONS AND TANGIBLE THINGS THAT MAY BE RELEVANT 

TO DISPUTED FACTS. 

 Defendant Sherman Financial 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; and (ii) 

notes of the agencies with whom Plaintiffs’ account was placed, received by Sherman 

Financial after Plaintiffs filed this action. 

Defendant Sherman Financial anticipates that Plaintiffs and the other named 

Defendants may also have documents, records, data and things that may be relevant to 

disputed facts. 

Defendant Sherman Financial may identify additional categories of documents, data 

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

Defendant Sherman Financial 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 Sherman Financial 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 34 Filed 07/26/06 Page 2 of 2