Exhibit 8

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 1 of 94 PageID 38
OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER PAGE 1 

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent § IN THE PROBATE COURT

Administrator of the Estate of § 

Evelyn Christine Grooms, Deceased, § 

§ 

Plaintiff, § 

§ 

VS. § NUMBER ONE

§ 

THE BANK OF NEW YORK MELLON § 

TRUST COMPANY, N.A. as Trustee for § 

Mortgage Assets Management Series I § 

Trust, and § 

COMPU-LINK CORPORATION DBA § 

CELINK, § 

§ 

Defendants. § TARRANT COUNTY, TEXAS

 

OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER

TO THE HONORABLE JUDGE OF SAID COURT: 

NOW Jerry J. Jarzombek, Movant, and files this Objection and Motion for Protective Order, 

and would respectfully show the Court the following: 

FACTS

1. On May 1, 2019 Defendants removed this case to the federal court for the Northern 

District of Texas. The case was identified in the federal court as Case No. 4:19-cv-00364-A (the 

‘federal case”). 

2. Various proceedings were held in the federal case, under it was remanded to this 

Court by Order dated June 23, 2020. See Exhibit A. A corresponding judgment entered the same 

day. See Exhibit B. 

3. The remand to this Court was based on the probated exception to jurisdiction and the 

Burford abstention doctrine. See Exhibit A. In the Order of Remand, the Court stated: “Pursuant to 

the probate exception, a federal court lacksjurisdiction to probate a will or administer an estate. See

E-FILED

TARRANT COUNTY, TEXAS

2/24/2021 11:57 PM

Mary Louise Nicholson

COUNTY CLERK

BY: Melissa Otts

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 2 of 94 PageID 39
OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER PAGE 2

Curtis v. Brunsting, 704 F. 3d 406, 408 (5th Cir. 2013).

4. The actions taken by Defendants in the federal case include the filing of a 

counterclaim and the addition of three third-party defendants: Jeffrey Ray Grooms (individually), 

Michael Grooms and Paula Grooms Davis.

5. On January 11, 2021, Defendants served discovery on the Plaintiff and each of the 

third-party defendants from the federal case, consisting for a Request for Disclosure, Request for 

Admission, Request for Production and Interrogatories. The discovery requests for Jeffrey Grooms 

(individually) are attached as Exhibits C, D, E and F; the discovery requests for Michael Grooms are 

attached as Exhibits G, H, I and J; and the discovery requests for Paula Grooms Davis are attached 

as Exhibits K, L, M and N.

6. By Agreed Order, the Defendants extended the deadline to respond to the discovery 

until February 24, 2021.

7. Movant states that these parties have not appeared in this case and seeks relief from 

having to respond to the non-party discovery.

ARGUMENTS & AUTHORITIES

8. Defendants make constant reference to a counterclaim and third-party defendants. A 

counterclaim has never been filed in this case, nor has a filing fee been paid for a counterclaim. The 

register of actions indicates that an amended counterclaim has been filed, but there is nothing to 

amend. The Court could consider the amended counterclaim, as the payment of the filing fee is not 

jurisdictional. Payment of a statutorily required filing fee “is not generally a prerequisite to 

jurisdiction, nor does the failure to pay such fees deprive the trial court of jurisdiction over a case.”

Nolte v. Flournoy, 348 S.W.3d 262, 271 (Tex. App.—Texarkana 2011, pet. denied) (citing J. Allen 

Family Partners, Ltd. v. Swain, No. 04-09-00384-CV, 2010 Tex. App. LEXIS 4116 (Tex. App.—

San Antonio May 26, 2010, no pet.) (mem. op.)); see Kapur v. Fondren Southwest Tempos Ass’n,

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 3 of 94 PageID 40
OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER PAGE 3

No. 01-13-00138-CV, 2013 Tex. App. LEXIS 12776, at *9-10 (Tex. App.—Houston [1st Dist.] Oct. 

15, 2013, no pet.) (mem. op.) (“A party need not pay a filing fee for the trial court to exercise 

jurisdiction over the claims”).

9. Third party practice is different from a counterclaim, and is described in Rule 38 of

the Texas Rules of Civil Procedure:

(a). When Defendant May Bring in Third Party. At any time after commencement of the

action a defending party, as a third-party plaintiff, may cause a citation and petition to be

served upon a person not a party to the action who is or may be liable to him or to the

plaintiff for all or part of the plaintiff's claim against him. The third-party plaintiff need not

obtain leave to make the service if he files the third-party petition not later than thirty (30)

days after he serves his original answer. Otherwise, he must obtain leave on motion upon

notice to all parties to the action. The person served, hereinafter called the third-party

defendant, shall make his defenses to the third-party plaintiff's claim under the rules

applicable to the defendant, and his counterclaims against the third-party plaintiff and crossclaims against other third-party defendants as provided in Rule 97.....

TEX. R. CIV. P. 38(a).

10. The record in this case does not contain a citation and petition served on Jeffrey Ray 

Grooms (individually), Michael Grooms and/or Paula Grooms Davis. No third-party defendants 

have ever been added in this case.

11. The logical anticipated response from Defendants might well be something related to 

the addition of third-party defendants in the federal case. On the facts before the Court, the addition 

of third-party defendants in the federal case does not survive remand – because the federal case was 

remanded based on a lack of subject matter jurisdiction. Should the trial court lack subject-matter 

jurisdiction, any order or judgment rendered by the trial court is void, rather than voidable. City of 

Dallas v. Redbird Dev. Corp., 143 S.W.3d 375, 380 (Tex. App.—Dallas 2004, no pet.); In r e United 

Automobile Ass’n, 307 S.W.3d 299, 309-10 (Tex. 2010); Mapco v. Forrest, 795 S.W.2d 700,703 

(Tex. 1990). The August 20, 2019 order in the federal case permitting the addition of third-party 

defendants is of no effect in the case before this Court.

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 4 of 94 PageID 41
OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER PAGE 4

12. As there are no third-party defendants before the Court, Movant seeks relief from 

having to respond to the voluminous discovery served upon him. Discovery in a case is served upon 

parties to the action unless it is clearly discovery to a non-party. The discovery at issue was served 

on the Movant, purporting to have Movant be the attorney representing each of the n on-parties. The 

Texas Rules of Civil Procedure define the scope of discovery:

(a) Generally. In general, a party may obtain discovery regarding any matter that is not 

privileged and is relevant to the subject matter of the pending action, whether it relates to the 

claim or defense of the party seeking discovery or the claim or defense of any other party. 

It is not a ground for objection that the information sought will be inadmissible at trial if the 

information sought appears reasonably calculated to lead to the discovery of admissible 

evidence. [emphasis added].

TEX. R. CIV. P. 192.3(a).

13. Based on the Texas Rules of Civil Procedure, Defendants’ discovery requests served 

on Movant for Jeffrey Ray Grooms (individually), Michael Grooms and/or Paula Grooms Davis

exceed the scope of discovery.

OBJECTION and MOTION FOR PROTECTIVE ORDER

14. The Court should order that the non-parties are not required to respond, object, nor 

assert privileges to the discovery requests attached to this motion as ExhibitsC through K, inclusive.

Movant objects to the discovery served on him and attached as Exhibit C through K as he is not the 

attorney for Jeffrey Ray Grooms (individually), Michael Grooms and/or Paula Grooms Davis – as 

the discovery exceeds the scope of discovery defined in the Texas Rules of Civil Procedure as they 

have not been added as third-party defendants to this case. Additionally, the record in this case does 

not show that Movant representsJeffrey Ray Grooms (individually), Michael Grooms and/or Paula 

Grooms Davis.

15. Alternatively, Movant seeks a protective order to protect him and the non-parties

from undue burden, unnecessary expense or annoyance, pursuant to TEX. R. CIV. P. 192.6(b). 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 5 of 94 PageID 42
OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER PAGE 5

Movant asks the Court for an Order relieving him of the need to respond to the discovery, based on 

TEX. R. CIV. P. 192.6(b)(1).

WHEREFORE, PREMISES CONSIDERED, Jerry J. Jarzombek, Movant, prays that the 

Court will sustain his objection to Defendants’ discovery requests served on him for Jeffrey Ray 

Grooms (individually), Michael Grooms and/or Paula Grooms Davis, non-parties to this case; grant 

Movant’s Motion for Protective Order, strike Defendants’ discovery served on January 11, 2021;

find the discovery to be abusive; order that Movant is relieved from any requirement to respond to

those discovery requests, and for such other and further relief to which Movant may be justly 

entitled.

Respectfully submitted,

/s/Jerry J. Jarzombek

Jerry J. Jarzombek

State Bar No. 10589050

The Law Office of Jerry Jarzombek, PLLC

6300 Ridglea Place, Suite 610

Fort Worth, Texas 76116

817-348-8325

817-348-8328 Facsimile

jerryjj@airmail.net

JoAnn H. Means

Lyster Law, PLLC

6300 Ridglea Place, Suite 610

Fort Worth, Texas 76116

joann@lysterlaw.com

817-738-7000

817-900-3331 Facsimile

ATTORNEYS FOR PLAINTIFF/

COUNTER-DEFENDANT

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 6 of 94 PageID 43
OBJECTION TO DEFENDENTS’ DISCOVERY REQUESTS

AND MOTION FOR PROTECTIVE ORDER PAGE 6

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the forgoing has been served on the following on this 

the 24th day of February, 2021:

Mr. Mark D. Cronenwett mcronenwett@mwzmlaw.com

Mackie Wolf Zientz & Mann, P.C.

14160 North Dallas Parkway, Suite 900

Dallas, Texas 75254

/s/ Jerry J. Jarzombek 

Jerry J. Jarzombek 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 7 of 94 PageID 44
IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

JEFFREY RAY GROOMS, INDEPENDENT § 

ADMINISTRATOR OF THE ESTATE OF § 

EVELYN CHRISTINE GROOMS, 

DECEASED, 

Plaintiff, 

vs. 

THE BANK OF NEW YORK MELLON 

§ 

§ 

§ 

§ 

§ 

§ NO. 4:19-CV-364-A 

§ 

§ 

TRUST COMPANY, N.A., AS TRUSTEE § 

FOR MORTGAGE ASSETS MANAGEMENT § 

SERIES I TRUST, ET AL., 

Defendants. 

§ 

§ 

§ 

ORDER 

U.S. DISTRICT COURT 

NORTHERN DISTRICT OF TllXAB 

FILED 

"~·-·~······~ 

JUN 2 3 2020 

-----· CLERK, U.S. D!STJUCT COURT 

ll~--,.,---.---- D~Jm1y 

By order signed June 8, 2020, the court noted its concern 

regarding jurisdiction over this case and ordered the parties to 

file briefs discussing whether the probate exception or Burford' 

abstention applies. The court has received and reviewed the 

responses and has determined that the case should be remanded to 

the probate court from which it was removed. 

Pursuant to the probate exception, a federal court lacks 

jurisdiction to probate a will or administer an estate. See 

Curtis v. Brunsting, 704 F. 3d 406, 408 (5th Cir. 2013). The 

exception also reserves to state probate courts the disposition 

of property in the custody of the state probate court. Id., 704 

F.3d at 409. To determine whether the probate exception deprives 

'Burford v. Sun Oil Co., 319 U.S. 315 (1943). 

Case 4:19-cv-00364-A Document 57 Filed 06/23/20 Page 1 of 5 PageID 612

Exhibit A

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 8 of 94 PageID 45
the court of jurisdiction, the court considers whether (1) the 

property in dispute is within the custody of the probate court, 

and (2) the plaintiff's claims would require the federal court 

to assume in rem jurisdiction over the property. Id. 

In this case, plaintiff, Jeffrey Ray Grooms, filed in the 

Probate Court No. 1 of Tarrant County, Texas, an application to 

determine heirship and for independent administration of his 

mother's estate.' He was granted letters of independent 

administration. Defendants, The Bank of New York Mellon Trust 

Company, N.A., as Trustee for Mortgage Assets Management Series 

I Trust, and Compu-Link Corporation, sent to plaintiff's 

attorney a notice of default and intent to accelerate, stating 

that the death of plaintiff's mother, Evelyn Christine Grooms, 

constituted an event of default under the terms of a reverse 

mortgage she had entered into after the death of her husband, 

Ray Grooms. Defendants posted the property that secured the 

mortgage loan for foreclosure and plaintiff filed a petition for 

temporary restraining order, which was docketed as an ancillary 

proceeding in the probate court. The probate court granted the 

temporary restraining order and plaintiff posted a cash bond. 

Defendants then filed a notice of removal, bringing the case 

before this court on the basis of diversity jurisdiction. 

2 Plaintiff is the only child of Ray Grooms, who died intestate on February 8, 

2001, and Evelyn Christine Grooms/ who died intestate on May 2, 2018. 

2 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 9 of 94 PageID 46 Case 4:19-cv-00364-A Document 57 Filed 06/23/20 Page 2 of 5 PageID 613
Plaintiff seeks a declaration that the lien sought to be 

enforced by defendants is not "foreclosure eligible" and is 

void. He also seeks a declaration of quiet title and to recover 

damages for defendants' alleged violations of the Texas Finance 

Code and Texas Deceptive Trade Practices-Consumer Protection 

Act. Defendants have filed a counterclaim and third-party 

complaint' seeking declaratory judgment that plaintiff's mother 

was the sole owner of the real property at issue and had the 

authority to enter into the reverse mortgage at issue. They also 

seek a judgment for foreclosure of the lien together with an 

order of sale directing the Tarrant County sheriff or constable 

to seize and sell the property, among other causes of action. 

In Texas, a probate court obtains jurisdiction of a 

decedent's estate when an administration is opened. Wybrants v. 

Lehman, 307 S.W.2d 339, 341 (Tex. Civ. App.-Eastland 1957, writ 

ref'd n.r.e.). It does not lose that jurisdiction until the 

estate is closed. Hawkins v. Estate of Volkmann, 898 S.W.2d 334, 

343 (Tex. App.-San Antonio 1994, writ denied). Although discrete 

matters may be determined, the administration of the estate from 

the filing of the application for probate or administration 

until the decree of final distribution and the discharge of the 

personal representative is considered as one proceeding for 

3 The third-party defendants, Paula Grooms Davis and Michael Grooms, are 

children of Ray Grooms and a wife who preceded Evelyn Christine Grooms. 

3 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 10 of 94 PageID 47 Case 4:19-cv-00364-A Document 57 Filed 06/23/20 Page 3 of 5 PageID 614
purposes of jurisdiction. Tex. Estates Code § 32.001(d) 

entire proceeding is a proceeding in rem." Id. 

"The 

In this case, the record reflects that a one-half interest 

in the real property at issue is property of the Estate of 

Evelyn Christine Grooms, which is within the custody of the 

probate court. (A matter related to a probate proceeding 

includes an action for trial of title to real property that is 

estate property, including the enforcement of a lien against the 

property. Tex. Estates Code§§ 31.002(a) (5) & (c) (1)). Both the 

claim and counterclaim would require this court to assume in rem 

jurisdiction over the property. Plaintiff seeks to quiet title 

and defendants seek to foreclose. Accordingly, the probate 

exception applies. Marshall v. Marshall, 547 U.S. 293, 311-12 

(2006). 

The court is also persuaded that Burford abstention would 

be appropriate in this case. The causes of action arise under 

state law. The case requires inquiry into unsettled issues of 

state law regarding reverse mortgages under the Texas 

Constitution. The State's interest involved and the need for a 

coherent policy regarding such mortgages are paramount. And, the 

probate court is the court of original jurisdiction for all 

matters concerning decedent's estates. Aransas Project v. Shaw, 

775 F. 3d 641, 649 (5th Cir. 2014); Moore v. State Farm Fire & 

Cas. Co., 556 F.3d 264, 272 (5th Cir. 2009) 

4 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 11 of 94 PageID 48 Case 4:19-cv-00364-A Document 57 Filed 06/23/20 Page 4 of 5 PageID 615
The court ORDERS that this case be, and is hereby, remanded 

to the Probate Court No. 1 of Tarrant County, Texas, from which 

it was removed. 

SIGNED June 23, 2020. 

5 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 12 of 94 PageID 49 Case 4:19-cv-00364-A Document 57 Filed 06/23/20 Page 5 of 5 PageID 616
IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

JEFFREY RAY GROOMS, INDEPENDENT § 

ADMINISTRATOR OF THE ESTATE OF § 

EVELYN CHRISTINE GROOMS, § 

DECEASED, § 

§ 

Plaintiff, § 

§ 

VS. § NO. 4:19-CV-364-A 

§ 

THE BANK OF NEW YORK MELLON § 

TRUST COMPANY, N.A., AS TRUSTEE§ 

FOR MORTGAGE ASSETS MANAGEMENT § 

SERIES I TRUST, ET AL., § 

§ 

Defendants. § 

FINAL JUDGMENT OF REMAND 

In accordance with the order signed this date, 

The court ORDERS, ADJUDGES, and DECREES that this case be, 

and is hereby, remanded to the Probate Court No. 1 of Tarrant 

County, Texas, from which it was removed. 

SIGNED June 23, 2020. 

Case 4:19-cv-00364-A Document 58 Filed 06/23/20 Page 1 of 1 PageID 617

Exhibit B

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 13 of 94 PageID 50
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 1 OF 5

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

§

§

§

§

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

REQUEST FOR DISCLOSURE TO THIRD-PARTY 

DEFENDANT JEFFREY GROOMS, INDIVIDUALLY 

To: Third-Party Defendant Jeffrey Grooms, Individually, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Pursuant to Rule 194, you are requested by Defendants/Counter-Plaintiffs/Third-Party 

Plaintiffs The Bank of New York Mellon Trust Company, N.A. as Trustee for Mortgage Assets 

Management Series I Trust, and Compu-Link Corporation d/b/a Celink to disclose within 30 

days of service of this request, the information or materials described in Rule 194.2.

Exhibit C

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 14 of 94 PageID 51
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 2 OF 5

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 15 of 94 PageID 52
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 3 OF 5

I. 

 INSTRUCTIONS

 In answering this Request for Disclosure, be advised that pursuant to Rule 191.3(a) of the 

Texas Rules of Civil Procedure, your disclosure must be signed either (1) by an attorney, if you 

are represented by an attorney, and must show the attorney’s State Bar of Texas identification 

number, address, telephone number, and fax number, if any, or (2) by you, if you are not 

represented by an attorney, and must show your address, telephone number, and fax number, if 

any. 

Be further advised that pursuant to Texas Rule of Civil Procedure 191.3(b), the signature 

of any attorney or party on a disclosure constitutes a certification that to the best of the signer’s 

knowledge, information, and belief, formed after a reasonable inquiry, the disclosure is complete 

and correct as of the time it is made. Be further advised that, pursuant to Texas Rule of Civil 

Procedure 191.3(d), if the response to this Request for Disclosures is not signed, it must be 

stricken unless it is signed promptly after the omission is called to the attention of the party 

making the Request for Disclosures. 

II. 

REQUEST FOR DISCLOSURE 

1. Pursuant to Texas Rule of Civil Procedure 194.2(a) disclose the correct names of the 

parties to the lawsuit: 

RESPONSE: 

2. Pursuant to Texas Rule of Civil Procedure 194.2(b) disclose the name, address, and 

telephone number of any potential parties: 

RESPONSE: 

3. Pursuant to Texas Rule of Civil Procedure 194.2(c) disclose the legal theories, and in 

general, the factual bases of your claims or defenses. 

RESPONSE: 

4. Pursuant to Texas Rule of Civil Procedure 194.2(d) disclose the amount and any method 

of calculating economic damages: 

RESPONSE: 

5. Pursuant to Texas Rule of Civil Procedure 194.2(e) disclose the name, address, and 

telephone number of persons having knowledge of relevant facts, and a brief statement of 

each identified person’s connection with the case: 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 16 of 94 PageID 53
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 4 OF 5

6. Pursuant to Texas Rule of Civil Procedure 194.2(f) for any testifying expert disclose the 

following: 

a. The expert’s name, address, and telephone number; 

b. The subject matter on which the expert will testify; 

c. The general substance of the expert’s mental impressions and opinions and a brief 

summary of the basis for them, or if the expert is not retained by, employed by, or 

otherwise subject to the control of the responding party, documents reflecting 

such information; 

d. If the expert is retained by, employed by, or otherwise subject to the control of the 

responding party: 

i. All documents, tangible things, reports, models, or date compilations that 

have been provided to, reviewed by, or prepared by or for the expert in 

anticipation of the expert’s testimony; and 

ii. The expert’s current resume and bibliography. 

RESPONSE: 

7. Pursuant to Texas Rule of Civil Procedure 194.2(g) disclose any discoverable indemnity 

and insuring agreements: 

RESPONSE: 

8. Pursuant to Texas Rule of Civil Procedure 194.2(h) disclose any discoverable settlement 

agreements: 

RESPONSE: 

9. Pursuant to Texas Rule of Civil Procedure 194.2(i) disclose any discoverable witness 

statements: 

RESPONSE: 

10. Pursuant to Texas Rule of Civil Procedure 194.2(j) disclose all medical records and bills 

that are reasonably related to the injuries or damages asserted or, in lieu thereof, an 

authorization permitting the disclosure of such medical records and bills: 

RESPONSE: 

11. Pursuant to Texas Rule of Civil Procedure 194.2(k) disclose all medical records and bills 

obtained by the responding party by virtue of an authorization furnished by the requesting 

party: 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 17 of 94 PageID 54
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 5 OF 5

12. Pursuant to Texas Rule of Civil Procedure 194.2(l) disclose the name, address, and 

telephone number of any person who may be designated as a responsible third party: 

RESPONSE:

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 18 of 94 PageID 55
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT JEFFRY RAY GROOMS, 

INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 1 OF 6

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

§

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

To: Third-Party Defendant Jeffrey Grooms, Individually, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant Jeffrey 

Grooms, Individually, answer in writing and under oath the following Requests for Admissions 

within thirty (30) days from the date of service hereof. A failure to respond may result in deemed 

admissions. 

Exhibit D

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 19 of 94 PageID 56
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT JEFFRY RAY GROOMS, 

INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 2 OF 6

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 20 of 94 PageID 57
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT JEFFRY RAY GROOMS, 

INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 3 OF 6

DEFINITIONS 

1. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

2. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

3. “Defendants” shall mean BNYM and Celink. 

4. “You,” “Your,” or “Yourself,” means Third-Party Defendant Jeffrey Grooms, 

Individually, and your agents and representatives. 

5. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

6. “Third-Party Defendants” shall mean Jeffrey Ray Grooms, Individually, Paula Grooms 

Davis, and Michael Grooms. 

7. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

8. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

9. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

10. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

11. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 21 of 94 PageID 58
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT JEFFRY RAY GROOMS, 

INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 4 OF 6

12. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

13. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

14. “Or” and “and” mean and/or. 

15. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

REQUESTS FOR ADMISSIONS 

REQUEST NO. 1: Admit that that you are not a party to the Loan. 

RESPONSE: 

REQUEST NO. 2: Admit the full and correct legal name of Ray Grooms is Jalmer Ray Grooms. 

RESPONSE: 

REQUEST NO. 3: Admit the full and correct legal name of Christine Grooms is Evelyn 

Christine Grooms. 

RESPONSE: 

REQUEST NO. 4: Admit the Affidavit of Heirship, recorded in the Official Public Records of 

Tarrant County, Texas at Instrument No. D201272988, contains the sole following real property 

description: 

LOT 19, 20, AND 21, MEADOW PARK ADDITION TO THE 

CITY OF WHITE SETTLEMENT, TARRANT COUNTY, 

TEXAS, ACCORDING TO THE PLAT RECORDED IN 

VOLUME 388-B, PAGE 209, PLAT RECORDS, TARRANT 

COUNTY, TEXAS. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 22 of 94 PageID 59
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT JEFFRY RAY GROOMS, 

INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 5 OF 6

REQUEST NO. 5: Admit that Christine Grooms entered into a Texas Home Equity Conversion 

Loan Agreement with Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B. on January 17, 2006. 

RESPONSE: 

REQUEST NO. 6: Admit Christine Grooms executed the Note on January 17, 2006. 

RESPONSE: 

REQUEST NO. 7: Admit Christine Grooms executed the Deed of Trust on January 17, 2006. 

RESPONSE: 

REQUEST NO. 8: Admit Christine Grooms executed an Adjustable Rate Second Note (Home 

Equity Conversion) on January 17, 2006. 

RESPONSE: 

REQUEST NO. 9: Admit Christine Grooms executed an Adjustable Rate Home Equity 

Conversion Second Deed of Trust on January 17, 2006. 

RESPONSE: 

REQUEST NO. 10: Admit Christine Grooms held herself out to be the sole owner of the 

Property when she entered into the Loan.

RESPONSE: 

REQUEST NO. 11: Admit you knew about the Loan on January 17, 2006. 

RESPONSE: 

REQUEST NO. 12: Admit you consented to the Loan. 

RESPONSE: 

REQUEST NO. 13: Admit you consented to the Lien created by the Deed of Trust. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 23 of 94 PageID 60
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT JEFFRY RAY GROOMS, 

INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 6 OF 6

REQUEST NO. 14: Admit Christine Grooms died on May 2, 2018.

RESPONSE: 

REQUEST NO. 15: Admit Christine Grooms died without a will and testament. 

RESPONSE: 

REQUEST NO. 16: Admit Defendants advanced funds to pay the ad valorem taxes on the 

Property in the amount of $404.05 on December 20, 2018. 

RESPONSE: 

REQUEST NO. 17: Defendants advanced funds to pay the ad valorem taxes on the Property in 

the amount of $464.96 on December 13, 2019. 

RESPONSE: 

REQUEST NO. 18: Admit Defendants have not foreclosed or sold the Property as of the date of 

your responses hereto. 

RESPONSE: 

REQUEST NO. 19: Admit you have not made any payments under the Loan Agreement. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 24 of 94 PageID 61
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 1 OF 9

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

To: Third-Party Defendant Jeffrey Ray Grooms, Individually, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant Jeffrey 

Ray Grooms, Individually, produce for inspection, copying, or photographing the following 

described documents and/or tangible things. Said production and inspection is to be made at the 

office of Defendants’ attorneys during regular business hours on or before thirty (30) days after 

Exhibit E

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 25 of 94 PageID 62
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 2 OF 9

service of these Requests for Production upon you. In the alternative, you may attach to your 

Response the original or duplicate of the documents and/or tangible things requested. 

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 26 of 94 PageID 63
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 3 OF 9

DEFINITIONS AND INSTRUCTIONS 

1. The term “documents” is used in the broadest sense of that term and includes the original 

and all non-identical copies, whether different from the original by reason of notations 

made on such copies or otherwise, and all drafts of: letters, telegrams, memoranda, 

reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call 

reports, financial and business records, receipts, contracts, reports, studies, calendar 

entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, 

statistical or informational accumulations, summaries or abstracts, any kind of records of 

meetings or conversations, firm impressions, sound or mechanical reproductions, rules, 

regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, 

publications, instructions, transparencies, handbooks, manuals, operating procedures, 

appointment calendars, call slips, file jackets, course materials, training materials, 

minutes, testimony, photographs, videotapes, films, press releases, speeches, surveys, 

graphs, statistics, tables, printed or typewritten forms, indices, agreements, canceled 

checks, correspondence, memos, telephone message slips, sketches, notes of 

conversations, and all other written, printed, typed or other reported matter, photographs, 

or other data compilations in which information can be obtained, which are in the 

possession, custody, or control of you, your attorneys, agents, physicians, directors, 

officers, partners, affiliates, subsidiaries, servants, or employees. Please note that 

“document” is also used to include documents, information or data on computer storage, 

data on computer disks, data stored on computer backup, electronic mail messages and 

other electronic correspondence, disks, electronic or magnetic recordings, Internet 

transmissions, Intranet transmissions, electronic bulletin boards, websites, diary systems, 

calendar systems, tickler systems and other information stored in, or accessible through 

computers, lap tops, hard drives, disks, or other information storage retrieval systems, 

together with instructions and all other materials necessary to use or interpret such data 

compilations in which information can be obtained, which are in the possession, custody, 

or control of you, your attorneys, agents, physicians, directors, officers, partners, 

affiliates, subsidiaries, servants, or employees. 

2. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

3. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

4. “Defendants” shall mean BNYM and Celink. 

5. “You,” “Your,” or “Yourself,” means Third-Party Defendant Jeffrey Ray Grooms, 

Individually and your agents and representatives. 

6. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 27 of 94 PageID 64
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 4 OF 9

7. “Plaintiff” shall mean and refer to Plaintiff/Counter-Defendant Jeffrey Ray Grooms, 

Independent Administrator of the Estate of Evelyn Christine Grooms, Deceased. 

8. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

9. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

10. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

11. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

12. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

13. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

14. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

15. “Or” and “and” mean and/or. 

16. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

17. “Person” or “persons” means not only natural persons, but also corporations, 

partnerships, organizations, associations, industry groups, entities, joint ventures, or any 

government or governmental entity, commission, or agency and any divisions or 

departments or other units of any of the entities defined herein. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 28 of 94 PageID 65
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 5 OF 9

18. “Relate” or “relating to” includes referring to, mentioning, reflecting, containing, 

pertaining to, evidencing, involving, describing, discussing, responding to, supporting, 

opposing, constituting or being a draft, copy or summary of, in whole or in part. 

19. You are to supplement or amend the Responses you give to this Request for Production 

as required by the Texas Rules of Civil Procedure. 

20. You are required to produce all documents requested within your possession, custody or 

control. Possession, custody or control includes constructive possession such that the 

person need not have actual physical possession. As long as the person has the superior 

right to compel the production from a third party (including an agency, authority or 

representative), the person has possession, custody or control. 

21. If any document was, but is no longer, in your possession, custody or control, state what 

disposition was made of it, by whom, and the date or dates or approximate date or dates 

on which such disposition was made and why. 

22. If you claim that any document for which production is requested is privileged, and 

therefore beyond the scope of discovery, for each document: 

 

a) Identify the document by specifying the date or approximate date of preparation, 

the nature of its contents, the name of its author, and the name and business 

address of its custodian. 

b) Specify the precise nature of the privilege claimed. 

23. To avoid ambiguity, significant effort has been spent to define a number of terms used in 

the following discovery requests. If you or your attorneys claim you do not understand 

the meaning of a term, please refer to the list of definitions or contact the opposing 

attorney for clarification. 

24. This discovery request is continuing. In the event that any information or material 

responsive to any Request comes to your attention, possession, custody, or control, or the 

attention, possession, custody or control of your agents, employees, affiliates, 

subsidiaries, accountants, partners, officers, family members, directors, or attorneys 

subsequent to the filing of your response, you are required to furnish the additional 

information, answers, or material to the opposing attorney as soon as possible. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 29 of 94 PageID 66
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 6 OF 9

REQUESTS FOR PRODUCTION 

REQUEST NO. 1: Produce all documents referenced in any of your responses to the 

Interrogatories from Defendants. 

 RESPONSE: 

REQUEST NO. 2: All documents which relate to the factual allegations in your First 

Amended Complaint, or any subsequent amendment or supplement thereto, including without 

limitation, written or recorded statements. 

 RESPONSE: 

REQUEST NO. 3: Each and every document, including records and emails, 

photographs, slides, pictures, videotapes, audiotapes, or other visual or graphic representations 

you intend to offer at the trial of this cause, including demonstrative exhibits. 

 RESPONSE: 

REQUEST NO. 4: Any and all documents which originated or emanated from BNYM 

and/or Celink, or which you contend would be construed as a document of Defendants that is in 

your possession, your attorney’s possession, or the possession of anyone assisting you in this 

case. 

 RESPONSE: 

REQUEST NO. 5: All documents evidencing or reflecting any communication by and 

between you and BNYM or any representative of BNYM related to the Loan or the Property. 

 RESPONSE: 

REQUEST NO. 6: All documents evidencing or reflecting any communication by and 

between you and Celink or any representative of Celink related to the Loan or the Property. 

 RESPONSE: 

REQUEST NO. 7: All documents evidencing or reflecting any communication by and 

between you and Plaintiff related to the Loan or the Property. 

 RESPONSE: 

 

REQUEST NO. 8: All documents, checks, coupons, or other financial statements, 

reflecting or evidencing the date, time, and/or amount of any or all payments made for ad 

valorem taxes on the Property from January 17, 2006 to date. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 30 of 94 PageID 67
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 7 OF 9

 RESPONSE: 

REQUEST NO. 9: With regard to all testifying experts that you intend to use in this 

case, all documents, tangible things, reports, models, or data compilations that have been 

provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s 

testimony. 

 RESPONSE: 

REQUEST NO. 10: With regard to all testifying experts that you intend to use in this 

case, the expert’s current resume, curriculum vitae, and/or bibliography. 

 RESPONSE: 

REQUEST NO. 11: Produce all information, materials, data compilations or documents 

reviewed or relied on in whole or in part by each expert whom you may call to testify at trial. 

 RESPONSE: 

REQUEST NO. 12: All the trial exhibits that you intend to use in this case. 

 RESPONSE: 

REQUEST NO. 13: All documents evidencing any alleged wrongdoing that you 

contend that BNYM and/or Celink engaged in. 

 RESPONSE: 

REQUEST NO. 14: All documents relating to or substantiating your claims for 

monetary damages. 

 RESPONSE: 

REQUEST NO. 15: All documents that constitute, evidence, refer or relate to any 

agreement or plan, whether oral or written, concerning any contingency fee arrangement and/or 

the payment of attorney fees in connection with this case. 

 RESPONSE: 

REQUEST NO. 16: All time records, including contemporaneous time sheets setting 

forth descriptions of the work performed on this case for which you or your attorneys will seek 

attorneys’ fees. 

 RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 31 of 94 PageID 68
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 8 OF 9

REQUEST NO. 17: All documents evidencing or reflecting any communication by and 

between you and Plaintiff related to the Affidavit of Heirship. 

 RESPONSE: 

REQUEST NO. 18: All documents that evidence, refer, or relate to any foreclosure 

proceeding against any Estate property, other than the subject Property at 801 Ala Drive, 

including any foreclosure proceeding that was threatened and/or anticipated but did not take 

place. 

 RESPONSE: 

REQUEST NO. 19: All documents that evidence, refer, or relate to real property owned 

in whole or in part by Jalmer Ray Grooms prior to his death, other than the subject Property at 

801 Ala Drive. 

 RESPONSE: 

REQUEST NO. 20: All documents that evidence, refer, or relate to real property owned 

in whole or in part by Evelyn Christine Grooms prior to her death, subject Property at 801 Ala 

Drive. 

 RESPONSE: 

REQUEST NO. 21: All notices of default, acceleration, or foreclosure that you received 

concerning the Property or Loan. 

 RESPONSE: 

REQUEST NO. 22: All documents reflecting the payment, in whole or in part, of any 

debts, whether secured or unsecured, specifically from the proceeds of the Loan. 

 RESPONSE: 

REQUEST NO. 23: If any funds/proceeds from the Loan were used to make repairs, 

changes, or improvements to the Property, produce all documents, checks, receipts, or other 

documentation reflecting same. 

 RESPONSE: 

REQUEST NO. 24: Any and all documents tending to support your claim the original 

lender on the Loan, Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., had knowledge or was aware of Plaintiff’s alleged interest in the Property as of 

January 17, 2006. 

 RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 32 of 94 PageID 69
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 9 OF 9

REQUEST NO. 25: Any and all documents tending to support your claim Defendants 

had knowledge or were aware of Plaintiff’s or Third-Party Defendants’ alleged interest in the 

Property prior to the death of Evelyn Christine Grooms. 

 RESPONSE: 

 REQUEST NO. 26: All documents that support your claim that “Defendants continue to 

make demands for payment despite not responding to the February 19, 2019 dispute.” 

 RESPONSE: 

 REQUEST NO. 27: All documents that support your claim that not all owners of the 

Property and their spouses consented to the Deed of Trust lien. 

 RESPONSE: 

 REQUEST NO. 28: All documents that support your claim that Defendants intended to 

abuse you or cause a serious upset of your daily life. 

 RESPONSE: 

 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 33 of 94 PageID 70
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 1 OF 7

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY 

DEFENDANT JEFFREY RAY GROOMS, INDIVIDUALLY 

To: Third-Party Defendant Jeffrey Grooms, Individually, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant Jeffrey 

Grooms, Individually, answer in writing and under oath the following set of Interrogatories 

within thirty (30) days from the date of service hereof. 

Exhibit F

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 34 of 94 PageID 71
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 2 OF 7

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 3 OF 7

DEFINITIONS AND INSTRUCTIONS 

1. The term “documents” is used in the broadest sense of that term and includes the original 

and all non-identical copies, whether different from the original by reason of notations 

made on such copies or otherwise, and all drafts of: letters, telegrams, memoranda, 

reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call 

reports, financial and business records, receipts, contracts, reports, studies, calendar 

entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, 

statistical or informational accumulations, summaries or abstracts, any kind of records of 

meetings or conversations, firm impressions, sound or mechanical reproductions, rules, 

regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, 

publications, instructions, transparencies, handbooks, manuals, operating procedures, 

appointment calendars, call slips, file jackets, course materials, training materials, 

minutes, testimony, photographs, videotapes, films, press releases, speeches, surveys, 

graphs, statistics, tables, printed or typewritten forms, indices, agreements, canceled 

checks, correspondence, memos, telephone message slips, sketches, notes of 

conversations, and all other written, printed, typed or other reported matter, photographs, 

or other data compilations in which information can be obtained, which are in the 

possession, custody, or control of you, your attorneys, agents, physicians, directors, 

officers, partners, affiliates, subsidiaries, servants, or employees. Please note that 

“document” is also used to include documents, information or data on computer storage, 

data on computer disks, data stored on computer backup, electronic mail messages and 

other electronic correspondence, disks, electronic or magnetic recordings, Internet 

transmissions, Intranet transmissions, electronic bulletin boards, websites, diary systems, 

calendar systems, tickler systems and other information stored in, or accessible through 

computers, lap tops, hard drives, disks, or other information storage retrieval systems, 

together with instructions and all other materials necessary to use or interpret such data 

compilations in which information can be obtained, which are in the possession, custody, 

or control of you, your attorneys, agents, physicians, directors, officers, partners, 

affiliates, subsidiaries, servants, or employees. 

2. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

3. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

4. “Defendants” shall mean BNYM and Celink. 

5. “You,” “Your,” or “Yourself,” means Third-Party Defendant Jeffrey Grooms, 

Individually, and your agents and representatives. 

6. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 4 OF 7

7. “Plaintiff” shall mean and refer to Plaintiff/Counter-Defendant Jeffrey Ray Grooms, 

Independent Administrator of the Estate of Evelyn Christine Grooms, Deceased. 

8. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

9. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

10. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

11. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

12. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

13. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

14. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

15. “Or” and “and” mean and/or. 

16. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

17. “Person” or “persons” means not only natural persons, but also corporations, 

partnerships, organizations, associations, industry groups, entities, joint ventures, or any 

government or governmental entity, commission, or agency and any divisions or 

departments or other units of any of the entities defined herein. 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 5 OF 7

18. “Relate” or “relating to” includes referring to, mentioning, reflecting, containing, 

pertaining to, evidencing, involving, describing, discussing, responding to, supporting, 

opposing, constituting or being a draft, copy or summary of, in whole or in part. 

19. As to any Interrogatory that you refuse to answer or are unable to answer in whole or in 

part, for any reason, please state the grounds for your refusal or inability to answer. 

When you believe that a complete answer to a particular Interrogatory or part thereof is 

not possible, please answer each Interrogatory to the extent possible and furnish a 

statement explaining: (a) the reason for your inability to answer further; and (b) whatever 

information or knowledge you have concerning the unanswered portion. 

20. Furnish all information available to you and known by you, or in your possession, care, 

custody or control, or possession, care, custody, or control of your agents and/or 

attorneys, or appearing in your records. 

21. You shall supplement your answers or other responses to these Interrogatories. 

22. Should you exercise your option to produce business records in response to an 

Interrogatory, you shall specify with particularity the location and identity of the business 

records where the information requested is found. Such production of documents does 

not satisfy the obligation to answer an Interrogatory if information within the scope of the 

Interrogatory other than that contained in the documents is available to you. 

23. You shall quote each Interrogatory in full immediately preceding the corresponding 

response. Each answer, objection, or response to the Interrogatories shall be identified by 

the same number and subpart of the corresponding Interrogatory and shall appear in the 

same order as the corresponding Interrogatory. Subparts of each Interrogatory shall be 

answered separately to avoid overlooking part of the question. 

24. If a document responsive to any Interrogatory has been lost, mutilated, or destroyed, so 

state and identify each such document, and state to which Interrogatory(ies) the document 

would have been responsive. 

25. The definitions listed above are to be construed as broadly as possible to include the most 

information or documents responsive to the discovery requests propounded herein. 

26. To avoid ambiguity, significant effort has been spent to define a number of terms used in 

the following discovery requests. If you or your attorneys claim you do not understand 

the meaning of a term, please refer to the list of definitions or contact the opposing 

attorney for clarification. 

27. This discovery request is continuing. In the event that any information or material 

responsive to any Interrogatory or request for production comes to your attention, 

possession, custody, or control, or the attention, possession, custody or control of your 

agents, employees, affiliates, subsidiaries, accountants, partners, officers, family 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

JEFFREY RAY GROOMS, INDIVIDUALLY 

MWZM: 19-000001-984-1 PAGE 6 OF 7

members, directors, or attorneys subsequent to the filing of your response, you are 

required to furnish the additional information, answers, or material to the opposing 

attorney as soon as possible. 

INTERROGATORIES 

INTERROGATORY NO. 1: State the name and address of all persons whom you know or 

believe to have personal knowledge or discoverable information, factual information, documents, 

photographs or audio or visual information pertaining to any fact that relates in any way to any 

issue in this case, including those persons who may have impeaching information. For each such 

person, describe the subject or topic of the person’s knowledge and identify whether you will call 

this person as a witness at trial. 

ANSWER: 

INTERROGATORY NO. 2: Identify all persons you may or will call as a witness at the trial 

of this case including their current address, phone number and place of employment. 

ANSWER: 

INTERROGATORY NO. 3: List each and every instance when you, or someone acting on 

your behalf, contacted, whether by phone, email or other written correspondence BNYM or 

Celink regarding the issues which are the subject of this suit and, for each instance, state the date 

of such contact, who made the contact on behalf; the representative who was contacted, the 

identity of all persons present or with knowledge of each communication and the substance of 

any such contact or communication. 

ANSWER: 

INTERROGATORY NO. 4: Please list each and every instance when BNYM, Celink, or 

someone acting on their behalf, contacted you in any manner regarding the issues which are the 

subject of this suit and, for each instance, state the date of such contact, the representative who 

made the contact and the substance of any such communication. 

ANSWER: 

INTERROGATORY NO. 5: Identify each and every real property parcel, by street address and 

legal description, in which you have or had any partial or whole ownership interest from 

February 8, 2001 to date, including the dates when the ownership interest began and when it 

terminated, of applicable. 

ANSWER: 

INTERROGATORY NO. 6: Identify the date you first learned Christine Grooms took out the 

Loan, including in your answer the manner by which you discovered the existence of the Loan. 

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MWZM: 19-000001-984-1 PAGE 7 OF 7

ANSWER: 

INTERROGATORY NO. 7: Identify the date of and manner by which you first learned you 

may have an ownership interest in the Property. 

ANSWER: 

INTERROGATORY NO. 8: If you were married on January 17, 2006, identify your spouse 

and the dates of the marriage. 

ANSWER: 

INTERROGATORY NO. 9: Identify each and every instance when you, or someone acting on 

your behalf, communicated with Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. regarding the Loan or the Property and, for each instance, state the date of 

such contact, who made the contact on behalf; the representative who was contacted, the identity 

of all persons present or with knowledge of each communication and the substance of any such 

contact or communication

ANSWER: 

INTERROGATORY NO. 10: Identify each and every instance when you, or someone acting

on your behalf, communicated with Edward Scoular, P.E. or Independent Foundation Engineers, 

Inc. regarding the Property and, for each instance, state the date of such contact, who made the 

contact on behalf; the representative who was contacted, the identity of all persons present or 

with knowledge of each communication and the substance of any such contact or 

communication. 

ANSWER: 

INTERROGATORY NO. 11: Identify each and every instance when you, or someone acting

on your behalf, communicated with a contractor regarding repairs for the Property and, for each 

instance, identify the contractor, state the date of such contact, who made the contact on behalf; 

the representative who was contacted, the identity of all persons present or with knowledge of 

each communication and the substance of any such contact or communication 

ANSWER: 

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DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 1 OF 5

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

REQUEST FOR DISCLOSURE TO 

THIRD-PARTY DEFENDANT MICHAEL GROOMS 

To: Third-Party Defendant Michael Grooms, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Pursuant to Rule 194, you are requested by Defendants/Counter-Plaintiffs/Third-Party 

Plaintiffs The Bank of New York Mellon Trust Company, N.A. as Trustee for Mortgage Assets 

Management Series I Trust, and Compu-Link Corporation d/b/a Celink to disclose within 30 

days of service of this request, the information or materials described in Rule 194.2.

Exhibit G

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DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 2 OF 5

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

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DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 3 OF 5

I. 

 INSTRUCTIONS

 In answering this Request for Disclosure, be advised that pursuant to Rule 191.3(a) of the 

Texas Rules of Civil Procedure, your disclosure must be signed either (1) by an attorney, if you 

are represented by an attorney, and must show the attorney’s State Bar of Texas identification 

number, address, telephone number, and fax number, if any, or (2) by you, if you are not 

represented by an attorney, and must show your address, telephone number, and fax number, if 

any. 

Be further advised that pursuant to Texas Rule of Civil Procedure 191.3(b), the signature 

of any attorney or party on a disclosure constitutes a certification that to the best of the signer’s 

knowledge, information, and belief, formed after a reasonable inquiry, the disclosure is complete 

and correct as of the time it is made. Be further advised that, pursuant to Texas Rule of Civil 

Procedure 191.3(d), if the response to this Request for Disclosures is not signed, it must be 

stricken unless it is signed promptly after the omission is called to the attention of the party 

making the Request for Disclosures. 

II. 

REQUEST FOR DISCLOSURE 

1. Pursuant to Texas Rule of Civil Procedure 194.2(a) disclose the correct names of the 

parties to the lawsuit: 

RESPONSE: 

2. Pursuant to Texas Rule of Civil Procedure 194.2(b) disclose the name, address, and 

telephone number of any potential parties: 

RESPONSE: 

3. Pursuant to Texas Rule of Civil Procedure 194.2(c) disclose the legal theories, and in 

general, the factual bases of your claims or defenses. 

RESPONSE: 

4. Pursuant to Texas Rule of Civil Procedure 194.2(d) disclose the amount and any method 

of calculating economic damages: 

RESPONSE: 

5. Pursuant to Texas Rule of Civil Procedure 194.2(e) disclose the name, address, and 

telephone number of persons having knowledge of relevant facts, and a brief statement of 

each identified person’s connection with the case: 

RESPONSE: 

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6. Pursuant to Texas Rule of Civil Procedure 194.2(f) for any testifying expert disclose the 

following: 

a. The expert’s name, address, and telephone number; 

b. The subject matter on which the expert will testify; 

c. The general substance of the expert’s mental impressions and opinions and a brief 

summary of the basis for them, or if the expert is not retained by, employed by, or 

otherwise subject to the control of the responding party, documents reflecting 

such information; 

d. If the expert is retained by, employed by, or otherwise subject to the control of the 

responding party: 

i. All documents, tangible things, reports, models, or date compilations that 

have been provided to, reviewed by, or prepared by or for the expert in 

anticipation of the expert’s testimony; and 

ii. The expert’s current resume and bibliography. 

RESPONSE: 

7. Pursuant to Texas Rule of Civil Procedure 194.2(g) disclose any discoverable indemnity 

and insuring agreements: 

RESPONSE: 

8. Pursuant to Texas Rule of Civil Procedure 194.2(h) disclose any discoverable settlement 

agreements: 

RESPONSE: 

9. Pursuant to Texas Rule of Civil Procedure 194.2(i) disclose any discoverable witness 

statements: 

RESPONSE: 

10. Pursuant to Texas Rule of Civil Procedure 194.2(j) disclose all medical records and bills 

that are reasonably related to the injuries or damages asserted or, in lieu thereof, an 

authorization permitting the disclosure of such medical records and bills: 

RESPONSE: 

11. Pursuant to Texas Rule of Civil Procedure 194.2(k) disclose all medical records and bills 

obtained by the responding party by virtue of an authorization furnished by the requesting 

party: 

RESPONSE: 

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12. Pursuant to Texas Rule of Civil Procedure 194.2(l) disclose the name, address, and 

telephone number of any person who may be designated as a responsible third party: 

RESPONSE:

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DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 1 OF 6

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ REQUESTS FOR ADMISSIONS 

TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

To: Third-Party Defendant Michael Grooms, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant 

Michael Grooms, answer in writing and under oath the following Requests for Admissions 

within thirty (30) days from the date of service hereof. A failure to respond may result in deemed 

admissions. 

Exhibit H

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DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 2 OF 6

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

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DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

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DEFINITIONS 

1. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

2. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

3. “Defendants” shall mean BNYM and Celink. 

4. “You,” “Your,” or “Yourself,” means Third-Party Defendant Michael Grooms, and your 

agents and representatives. 

5. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

6. “Third-Party Defendants” shall mean Jeffrey Ray Grooms, Individually, Paula Grooms 

Davis, and Michael Grooms. 

7. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

8. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

9. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

10. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

11. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

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12. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

13. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

14. “Or” and “and” mean and/or. 

15. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

REQUESTS FOR ADMISSIONS 

REQUEST NO. 1: Admit that that you are not a party to the Loan. 

RESPONSE: 

REQUEST NO. 2: Admit the full and correct legal name of Ray Grooms is Jalmer Ray Grooms. 

RESPONSE: 

REQUEST NO. 3: Admit the full and correct legal name of Christine Grooms is Evelyn 

Christine Grooms. 

RESPONSE: 

REQUEST NO. 4: Admit the Affidavit of Heirship, recorded in the Official Public Records of 

Tarrant County, Texas at Instrument No. D201272988, contains the sole following real property 

description: 

LOT 19, 20, AND 21, MEADOW PARK ADDITION TO THE 

CITY OF WHITE SETTLEMENT, TARRANT COUNTY, 

TEXAS, ACCORDING TO THE PLAT RECORDED IN 

VOLUME 388-B, PAGE 209, PLAT RECORDS, TARRANT 

COUNTY, TEXAS. 

RESPONSE: 

REQUEST NO. 5: Admit that Christine Grooms entered into a Texas Home Equity Conversion 

Loan Agreement with Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B. on January 17, 2006. 

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RESPONSE: 

REQUEST NO. 6: Admit Christine Grooms executed the Note on January 17, 2006. 

RESPONSE: 

REQUEST NO. 7: Admit Christine Grooms executed the Deed of Trust on January 17, 2006. 

RESPONSE: 

REQUEST NO. 8: Admit Christine Grooms executed an Adjustable Rate Second Note (Home 

Equity Conversion) on January 17, 2006. 

RESPONSE: 

REQUEST NO. 9: Admit Christine Grooms executed an Adjustable Rate Home Equity 

Conversion Second Deed of Trust on January 17, 2006. 

RESPONSE: 

REQUEST NO. 10: Admit Christine Grooms held herself out to be the sole owner of the 

Property when she entered into the Loan.

RESPONSE: 

REQUEST NO. 11: Admit you knew about the Loan on January 17, 2006. 

RESPONSE: 

REQUEST NO. 12: Admit you consented to the Loan. 

RESPONSE: 

REQUEST NO. 13: Admit you consented to the Lien created by the Deed of Trust. 

RESPONSE: 

REQUEST NO. 14: Admit Christine Grooms died on May 2, 2018.

RESPONSE: 

REQUEST NO. 15: Admit Christine Grooms died without a will and testament. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 50 of 94 PageID 87
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 6 OF 6

REQUEST NO. 16: Admit Defendants advanced funds to pay the ad valorem taxes on the 

Property in the amount of $404.05 on December 20, 2018. 

RESPONSE: 

REQUEST NO. 17: Defendants advanced funds to pay the ad valorem taxes on the Property in 

the amount of $464.96 on December 13, 2019. 

RESPONSE: 

REQUEST NO. 18: Admit Defendants have not foreclosed or sold the Property as of the date of 

your responses hereto. 

RESPONSE: 

REQUEST NO. 19: Admit you have not made any payments under the Loan Agreement. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 51 of 94 PageID 88
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 1 OF 9

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

To: Third-Party Defendant Michael Grooms, Individually, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant 

Michael Grooms, produce for inspection, copying, or photographing the following described 

documents and/or tangible things. Said production and inspection is to be made at the office of 

Defendants’ attorneys during regular business hours on or before thirty (30) days after service of 

Exhibit I

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 52 of 94 PageID 89
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 2 OF 9

these Requests for Production upon you. In the alternative, you may attach to your Response the 

original or duplicate of the documents and/or tangible things requested. 

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 53 of 94 PageID 90
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 3 OF 9

DEFINITIONS AND INSTRUCTIONS 

1. The term “documents” is used in the broadest sense of that term and includes the original 

and all non-identical copies, whether different from the original by reason of notations 

made on such copies or otherwise, and all drafts of: letters, telegrams, memoranda, 

reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call 

reports, financial and business records, receipts, contracts, reports, studies, calendar 

entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, 

statistical or informational accumulations, summaries or abstracts, any kind of records of 

meetings or conversations, firm impressions, sound or mechanical reproductions, rules, 

regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, 

publications, instructions, transparencies, handbooks, manuals, operating procedures, 

appointment calendars, call slips, file jackets, course materials, training materials, 

minutes, testimony, photographs, videotapes, films, press releases, speeches, surveys, 

graphs, statistics, tables, printed or typewritten forms, indices, agreements, canceled 

checks, correspondence, memos, telephone message slips, sketches, notes of 

conversations, and all other written, printed, typed or other reported matter, photographs, 

or other data compilations in which information can be obtained, which are in the 

possession, custody, or control of you, your attorneys, agents, physicians, directors, 

officers, partners, affiliates, subsidiaries, servants, or employees. Please note that 

“document” is also used to include documents, information or data on computer storage, 

data on computer disks, data stored on computer backup, electronic mail messages and 

other electronic correspondence, disks, electronic or magnetic recordings, Internet 

transmissions, Intranet transmissions, electronic bulletin boards, websites, diary systems, 

calendar systems, tickler systems and other information stored in, or accessible through 

computers, lap tops, hard drives, disks, or other information storage retrieval systems, 

together with instructions and all other materials necessary to use or interpret such data 

compilations in which information can be obtained, which are in the possession, custody, 

or control of you, your attorneys, agents, physicians, directors, officers, partners, 

affiliates, subsidiaries, servants, or employees. 

2. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

3. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

4. “Defendants” shall mean BNYM and Celink. 

5. “You,” “Your,” or “Yourself,” means Third-Party Defendant Michael Grooms, and your 

agents and representatives. 

6. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 54 of 94 PageID 91
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 4 OF 9

7. “Plaintiff” shall mean and refer to Plaintiff/Counter-Defendant Jeffrey Ray Grooms, 

Independent Administrator of the Estate of Evelyn Christine Grooms, Deceased. 

8. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

9. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

10. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

11. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

12. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

13. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

14. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

15. “Or” and “and” mean and/or. 

16. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

17. “Person” or “persons” means not only natural persons, but also corporations, 

partnerships, organizations, associations, industry groups, entities, joint ventures, or any 

government or governmental entity, commission, or agency and any divisions or 

departments or other units of any of the entities defined herein. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 55 of 94 PageID 92
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 5 OF 9

18. “Relate” or “relating to” includes referring to, mentioning, reflecting, containing, 

pertaining to, evidencing, involving, describing, discussing, responding to, supporting, 

opposing, constituting or being a draft, copy or summary of, in whole or in part. 

19. You are to supplement or amend the Responses you give to this Request for Production 

as required by the Texas Rules of Civil Procedure. 

20. You are required to produce all documents requested within your possession, custody or 

control. Possession, custody or control includes constructive possession such that the 

person need not have actual physical possession. As long as the person has the superior 

right to compel the production from a third party (including an agency, authority or 

representative), the person has possession, custody or control. 

21. If any document was, but is no longer, in your possession, custody or control, state what 

disposition was made of it, by whom, and the date or dates or approximate date or dates 

on which such disposition was made and why. 

22. If you claim that any document for which production is requested is privileged, and 

therefore beyond the scope of discovery, for each document: 

 

a) Identify the document by specifying the date or approximate date of preparation, 

the nature of its contents, the name of its author, and the name and business 

address of its custodian. 

b) Specify the precise nature of the privilege claimed. 

23. To avoid ambiguity, significant effort has been spent to define a number of terms used in 

the following discovery requests. If you or your attorneys claim you do not understand 

the meaning of a term, please refer to the list of definitions or contact the opposing 

attorney for clarification. 

24. This discovery request is continuing. In the event that any information or material 

responsive to any Request comes to your attention, possession, custody, or control, or the 

attention, possession, custody or control of your agents, employees, affiliates, 

subsidiaries, accountants, partners, officers, family members, directors, or attorneys 

subsequent to the filing of your response, you are required to furnish the additional 

information, answers, or material to the opposing attorney as soon as possible. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 56 of 94 PageID 93
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 6 OF 9

REQUESTS FOR PRODUCTION 

REQUEST NO. 1: Produce all documents referenced in any of your responses to the 

Interrogatories from Defendants. 

 RESPONSE: 

REQUEST NO. 2: All documents which relate to the factual allegations in your First 

Amended Complaint, or any subsequent amendment or supplement thereto, including without 

limitation, written or recorded statements. 

 RESPONSE: 

REQUEST NO. 3: Each and every document, including records and emails, 

photographs, slides, pictures, videotapes, audiotapes, or other visual or graphic representations 

you intend to offer at the trial of this cause, including demonstrative exhibits. 

 RESPONSE: 

REQUEST NO. 4: Any and all documents which originated or emanated from BNYM 

and/or Celink, or which you contend would be construed as a document of Defendants that is in 

your possession, your attorney’s possession, or the possession of anyone assisting you in this 

case. 

 RESPONSE: 

REQUEST NO. 5: All documents evidencing or reflecting any communication by and 

between you and BNYM or any representative of BNYM related to the Loan or the Property. 

 RESPONSE: 

REQUEST NO. 6: All documents evidencing or reflecting any communication by and 

between you and Celink or any representative of Celink related to the Loan or the Property. 

 RESPONSE: 

REQUEST NO. 7: All documents evidencing or reflecting any communication by and 

between you and Plaintiff related to the Loan or the Property. 

 RESPONSE: 

 

REQUEST NO. 8: All documents, checks, coupons, or other financial statements, 

reflecting or evidencing the date, time, and/or amount of any or all payments made for ad 

valorem taxes on the Property from January 17, 2006 to date. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 57 of 94 PageID 94
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 7 OF 9

 RESPONSE: 

REQUEST NO. 9: With regard to all testifying experts that you intend to use in this 

case, all documents, tangible things, reports, models, or data compilations that have been 

provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s 

testimony. 

 RESPONSE: 

REQUEST NO. 10: With regard to all testifying experts that you intend to use in this 

case, the expert’s current resume, curriculum vitae, and/or bibliography. 

 RESPONSE: 

REQUEST NO. 11: Produce all information, materials, data compilations or documents 

reviewed or relied on in whole or in part by each expert whom you may call to testify at trial. 

 RESPONSE: 

REQUEST NO. 12: All the trial exhibits that you intend to use in this case. 

 RESPONSE: 

REQUEST NO. 13: All documents evidencing any alleged wrongdoing that you 

contend that BNYM and/or Celink engaged in. 

 RESPONSE: 

REQUEST NO. 14: All documents relating to or substantiating your claims for 

monetary damages. 

 RESPONSE: 

REQUEST NO. 15: All documents that constitute, evidence, refer or relate to any 

agreement or plan, whether oral or written, concerning any contingency fee arrangement and/or 

the payment of attorney fees in connection with this case. 

 RESPONSE: 

REQUEST NO. 16: All time records, including contemporaneous time sheets setting 

forth descriptions of the work performed on this case for which you or your attorneys will seek 

attorneys’ fees. 

 RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 58 of 94 PageID 95
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 8 OF 9

REQUEST NO. 17: All documents evidencing or reflecting any communication by and 

between you and Plaintiff related to the Affidavit of Heirship. 

 RESPONSE: 

REQUEST NO. 18: All documents that evidence, refer, or relate to any foreclosure 

proceeding against any Estate property, other than the subject Property at 801 Ala Drive, 

including any foreclosure proceeding that was threatened and/or anticipated but did not take 

place. 

 RESPONSE: 

REQUEST NO. 19: All documents that evidence, refer, or relate to real property owned 

in whole or in part by Jalmer Ray Grooms prior to his death, other than the subject Property at 

801 Ala Drive. 

 RESPONSE: 

REQUEST NO. 20: All documents that evidence, refer, or relate to real property owned 

in whole or in part by Evelyn Christine Grooms prior to her death, subject Property at 801 Ala 

Drive. 

 RESPONSE: 

REQUEST NO. 21: All notices of default, acceleration, or foreclosure that you received 

concerning the Property or Loan. 

 RESPONSE: 

REQUEST NO. 22: All documents reflecting the payment, in whole or in part, of any 

debts, whether secured or unsecured, specifically from the proceeds of the Loan. 

 RESPONSE: 

REQUEST NO. 23: If any funds/proceeds from the Loan were used to make repairs, 

changes, or improvements to the Property, produce all documents, checks, receipts, or other 

documentation reflecting same. 

 RESPONSE: 

REQUEST NO. 24: Any and all documents tending to support your claim the original 

lender on the Loan, Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., had knowledge or was aware of Plaintiff’s alleged interest in the Property as of 

January 17, 2006. 

 RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 59 of 94 PageID 96
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 9 OF 9

REQUEST NO. 25: Any and all documents tending to support your claim Defendants 

had knowledge or were aware of Plaintiff’s or Third-Party Defendants’ alleged interest in the 

Property prior to the death of Evelyn Christine Grooms. 

 RESPONSE: 

 REQUEST NO. 26: All documents that support your claim that “Defendants continue to 

make demands for payment despite not responding to the February 19, 2019 dispute.” 

 RESPONSE: 

 REQUEST NO. 27: All documents that support your claim that not all owners of the 

Property and their spouses consented to the Deed of Trust lien. 

 RESPONSE: 

 REQUEST NO. 28: All documents that support your claim that Defendants intended to 

abuse you or cause a serious upset of your daily life. 

 RESPONSE: 

 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 60 of 94 PageID 97
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 1 OF 7

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ FIRST INTERROGATORIES TO 

THIRD-PARTY DEFENDANT MICHAEL GROOMS 

To: Third-Party Defendant Michael Grooms, Individually, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant 

Michael Grooms, answer in writing and under oath the following set of Interrogatories within 

thirty (30) days from the date of service hereof. 

Exhibit J

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 61 of 94 PageID 98
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 2 OF 7

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 62 of 94 PageID 99
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 3 OF 7

DEFINITIONS AND INSTRUCTIONS 

1. The term “documents” is used in the broadest sense of that term and includes the original 

and all non-identical copies, whether different from the original by reason of notations 

made on such copies or otherwise, and all drafts of: letters, telegrams, memoranda, 

reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call 

reports, financial and business records, receipts, contracts, reports, studies, calendar 

entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, 

statistical or informational accumulations, summaries or abstracts, any kind of records of 

meetings or conversations, firm impressions, sound or mechanical reproductions, rules, 

regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, 

publications, instructions, transparencies, handbooks, manuals, operating procedures, 

appointment calendars, call slips, file jackets, course materials, training materials, 

minutes, testimony, photographs, videotapes, films, press releases, speeches, surveys, 

graphs, statistics, tables, printed or typewritten forms, indices, agreements, canceled 

checks, correspondence, memos, telephone message slips, sketches, notes of 

conversations, and all other written, printed, typed or other reported matter, photographs, 

or other data compilations in which information can be obtained, which are in the 

possession, custody, or control of you, your attorneys, agents, physicians, directors, 

officers, partners, affiliates, subsidiaries, servants, or employees. Please note that 

“document” is also used to include documents, information or data on computer storage, 

data on computer disks, data stored on computer backup, electronic mail messages and 

other electronic correspondence, disks, electronic or magnetic recordings, Internet 

transmissions, Intranet transmissions, electronic bulletin boards, websites, diary systems, 

calendar systems, tickler systems and other information stored in, or accessible through 

computers, lap tops, hard drives, disks, or other information storage retrieval systems, 

together with instructions and all other materials necessary to use or interpret such data 

compilations in which information can be obtained, which are in the possession, custody, 

or control of you, your attorneys, agents, physicians, directors, officers, partners, 

affiliates, subsidiaries, servants, or employees. 

2. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

3. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

4. “Defendants” shall mean BNYM and Celink. 

5. “You,” “Your,” or “Yourself,” means Third-Party Defendant Michael Grooms, and your 

agents and representatives. 

6. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 63 of 94 PageID 100
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 4 OF 7

7. “Plaintiff” shall mean and refer to Plaintiff/Counter-Defendant Jeffrey Ray Grooms, 

Independent Administrator of the Estate of Evelyn Christine Grooms, Deceased. 

8. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

9. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

10. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

11. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

12. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

13. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

14. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

15. “Or” and “and” mean and/or. 

16. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

17. “Person” or “persons” means not only natural persons, but also corporations, 

partnerships, organizations, associations, industry groups, entities, joint ventures, or any 

government or governmental entity, commission, or agency and any divisions or 

departments or other units of any of the entities defined herein. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 64 of 94 PageID 101
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 5 OF 7

18. “Relate” or “relating to” includes referring to, mentioning, reflecting, containing, 

pertaining to, evidencing, involving, describing, discussing, responding to, supporting, 

opposing, constituting or being a draft, copy or summary of, in whole or in part. 

19. As to any Interrogatory that you refuse to answer or are unable to answer in whole or in 

part, for any reason, please state the grounds for your refusal or inability to answer. 

When you believe that a complete answer to a particular Interrogatory or part thereof is 

not possible, please answer each Interrogatory to the extent possible and furnish a 

statement explaining: (a) the reason for your inability to answer further; and (b) whatever 

information or knowledge you have concerning the unanswered portion. 

20. Furnish all information available to you and known by you, or in your possession, care, 

custody or control, or possession, care, custody, or control of your agents and/or 

attorneys, or appearing in your records. 

21. You shall supplement your answers or other responses to these Interrogatories. 

22. Should you exercise your option to produce business records in response to an 

Interrogatory, you shall specify with particularity the location and identity of the business 

records where the information requested is found. Such production of documents does 

not satisfy the obligation to answer an Interrogatory if information within the scope of the 

Interrogatory other than that contained in the documents is available to you. 

23. You shall quote each Interrogatory in full immediately preceding the corresponding 

response. Each answer, objection, or response to the Interrogatories shall be identified by 

the same number and subpart of the corresponding Interrogatory and shall appear in the 

same order as the corresponding Interrogatory. Subparts of each Interrogatory shall be 

answered separately to avoid overlooking part of the question. 

24. If a document responsive to any Interrogatory has been lost, mutilated, or destroyed, so 

state and identify each such document, and state to which Interrogatory(ies) the document 

would have been responsive. 

25. The definitions listed above are to be construed as broadly as possible to include the most 

information or documents responsive to the discovery requests propounded herein. 

26. To avoid ambiguity, significant effort has been spent to define a number of terms used in 

the following discovery requests. If you or your attorneys claim you do not understand 

the meaning of a term, please refer to the list of definitions or contact the opposing 

attorney for clarification. 

27. This discovery request is continuing. In the event that any information or material 

responsive to any Interrogatory or request for production comes to your attention, 

possession, custody, or control, or the attention, possession, custody or control of your 

agents, employees, affiliates, subsidiaries, accountants, partners, officers, family 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 65 of 94 PageID 102
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 6 OF 7

members, directors, or attorneys subsequent to the filing of your response, you are 

required to furnish the additional information, answers, or material to the opposing 

attorney as soon as possible. 

INTERROGATORIES 

INTERROGATORY NO. 1: State the name and address of all persons whom you know or 

believe to have personal knowledge or discoverable information, factual information, documents, 

photographs or audio or visual information pertaining to any fact that relates in any way to any 

issue in this case, including those persons who may have impeaching information. For each such 

person, describe the subject or topic of the person’s knowledge and identify whether you will call 

this person as a witness at trial. 

ANSWER: 

INTERROGATORY NO. 2: Identify all persons you may or will call as a witness at the trial 

of this case including their current address, phone number and place of employment. 

ANSWER: 

INTERROGATORY NO. 3: List each and every instance when you, or someone acting on 

your behalf, contacted, whether by phone, email or other written correspondence BNYM or 

Celink regarding the issues which are the subject of this suit and, for each instance, state the date 

of such contact, who made the contact on behalf; the representative who was contacted, the 

identity of all persons present or with knowledge of each communication and the substance of 

any such contact or communication. 

ANSWER: 

INTERROGATORY NO. 4: Please list each and every instance when BNYM, Celink, or 

someone acting on their behalf, contacted you in any manner regarding the issues which are the 

subject of this suit and, for each instance, state the date of such contact, the representative who 

made the contact and the substance of any such communication. 

ANSWER: 

INTERROGATORY NO. 5: Identify each and every real property parcel, by street address and 

legal description, in which you have or had any partial or whole ownership interest from 

February 8, 2001 to date, including the dates when the ownership interest began and when it 

terminated, of applicable. 

ANSWER: 

INTERROGATORY NO. 6: Identify the date you first learned Christine Grooms took out the 

Loan, including in your answer the manner by which you discovered the existence of the Loan. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 66 of 94 PageID 103
DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

 MICHAEL GROOMS 

MWZM: 19-000001-984-1 PAGE 7 OF 7

ANSWER: 

INTERROGATORY NO. 7: Identify the date of and manner by which you first learned you 

may have an ownership interest in the Property. 

ANSWER: 

INTERROGATORY NO. 8: If you were married on January 17, 2006, identify your spouse 

and the dates of the marriage. 

ANSWER: 

INTERROGATORY NO. 9: Identify each and every instance when you, or someone acting on 

your behalf, communicated with Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. regarding the Loan or the Property and, for each instance, state the date of 

such contact, who made the contact on behalf; the representative who was contacted, the identity 

of all persons present or with knowledge of each communication and the substance of any such 

contact or communication

ANSWER: 

INTERROGATORY NO. 10: Identify each and every instance when you, or someone acting

on your behalf, communicated with Edward Scoular, P.E. or Independent Foundation Engineers, 

Inc. regarding the Property and, for each instance, state the date of such contact, who made the 

contact on behalf; the representative who was contacted, the identity of all persons present or 

with knowledge of each communication and the substance of any such contact or 

communication. 

ANSWER: 

INTERROGATORY NO. 11: Identify each and every instance when you, or someone acting

on your behalf, communicated with a contractor regarding repairs for the Property and, for each 

instance, identify the contractor, state the date of such contact, who made the contact on behalf; 

the representative who was contacted, the identity of all persons present or with knowledge of 

each communication and the substance of any such contact or communication 

ANSWER: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 67 of 94 PageID 104
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 1 OF 5

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

REQUEST FOR DISCLOSURE TO 

THIRD-PARTY DEFENDANT PAULA GROOMS DAVIS

To: Third-Party Defendant Paula Grooms Davis, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Pursuant to Rule 194, you are requested by Defendants/Counter-Plaintiffs/Third-Party 

Plaintiffs The Bank of New York Mellon Trust Company, N.A. as Trustee for Mortgage Assets 

Management Series I Trust, and Compu-Link Corporation d/b/a Celink to disclose within 30 

days of service of this request, the information or materials described in Rule 194.2.

Exhibit K

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 68 of 94 PageID 105
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 2 OF 5

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 69 of 94 PageID 106
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 3 OF 5

I. 

 INSTRUCTIONS

 In answering this Request for Disclosure, be advised that pursuant to Rule 191.3(a) of the 

Texas Rules of Civil Procedure, your disclosure must be signed either (1) by an attorney, if you 

are represented by an attorney, and must show the attorney’s State Bar of Texas identification 

number, address, telephone number, and fax number, if any, or (2) by you, if you are not 

represented by an attorney, and must show your address, telephone number, and fax number, if 

any. 

Be further advised that pursuant to Texas Rule of Civil Procedure 191.3(b), the signature 

of any attorney or party on a disclosure constitutes a certification that to the best of the signer’s 

knowledge, information, and belief, formed after a reasonable inquiry, the disclosure is complete 

and correct as of the time it is made. Be further advised that, pursuant to Texas Rule of Civil 

Procedure 191.3(d), if the response to this Request for Disclosures is not signed, it must be 

stricken unless it is signed promptly after the omission is called to the attention of the party 

making the Request for Disclosures. 

II. 

REQUEST FOR DISCLOSURE 

1. Pursuant to Texas Rule of Civil Procedure 194.2(a) disclose the correct names of the 

parties to the lawsuit: 

RESPONSE: 

2. Pursuant to Texas Rule of Civil Procedure 194.2(b) disclose the name, address, and 

telephone number of any potential parties: 

RESPONSE: 

3. Pursuant to Texas Rule of Civil Procedure 194.2(c) disclose the legal theories, and in 

general, the factual bases of your claims or defenses. 

RESPONSE: 

4. Pursuant to Texas Rule of Civil Procedure 194.2(d) disclose the amount and any method 

of calculating economic damages: 

RESPONSE: 

5. Pursuant to Texas Rule of Civil Procedure 194.2(e) disclose the name, address, and 

telephone number of persons having knowledge of relevant facts, and a brief statement of 

each identified person’s connection with the case: 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 70 of 94 PageID 107
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 4 OF 5

6. Pursuant to Texas Rule of Civil Procedure 194.2(f) for any testifying expert disclose the 

following: 

a. The expert’s name, address, and telephone number; 

b. The subject matter on which the expert will testify; 

c. The general substance of the expert’s mental impressions and opinions and a brief 

summary of the basis for them, or if the expert is not retained by, employed by, or 

otherwise subject to the control of the responding party, documents reflecting 

such information; 

d. If the expert is retained by, employed by, or otherwise subject to the control of the 

responding party: 

i. All documents, tangible things, reports, models, or date compilations that 

have been provided to, reviewed by, or prepared by or for the expert in 

anticipation of the expert’s testimony; and 

ii. The expert’s current resume and bibliography. 

RESPONSE: 

7. Pursuant to Texas Rule of Civil Procedure 194.2(g) disclose any discoverable indemnity 

and insuring agreements: 

RESPONSE: 

8. Pursuant to Texas Rule of Civil Procedure 194.2(h) disclose any discoverable settlement 

agreements: 

RESPONSE: 

9. Pursuant to Texas Rule of Civil Procedure 194.2(i) disclose any discoverable witness 

statements: 

RESPONSE: 

10. Pursuant to Texas Rule of Civil Procedure 194.2(j) disclose all medical records and bills 

that are reasonably related to the injuries or damages asserted or, in lieu thereof, an 

authorization permitting the disclosure of such medical records and bills: 

RESPONSE: 

11. Pursuant to Texas Rule of Civil Procedure 194.2(k) disclose all medical records and bills 

obtained by the responding party by virtue of an authorization furnished by the requesting 

party: 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 71 of 94 PageID 108
DEFENDANTS’ REQUEST FOR DISCLOSURE TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 5 OF 5

12. Pursuant to Texas Rule of Civil Procedure 194.2(l) disclose the name, address, and 

telephone number of any person who may be designated as a responsible third party: 

RESPONSE:

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 72 of 94 PageID 109
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT PAULA GROOMS 

DAVIS 

MWZM: 19-000001-984-1 PAGE 1 OF 6

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ REQUESTS FOR ADMISSIONS 

TO THIRD-PARTY DEFENDANT PAULA GROOMS DAVIS 

To: Third-Party Defendant Paula Grooms Davis, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant Paula 

Grooms Davis, answer in writing and under oath the following Requests for Admissions within 

thirty (30) days from the date of service hereof. A failure to respond may result in deemed 

admissions. 

Exhibit L

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 73 of 94 PageID 110
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT PAULA GROOMS 

DAVIS 

MWZM: 19-000001-984-1 PAGE 2 OF 6

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 74 of 94 PageID 111
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT PAULA GROOMS 

DAVIS 

MWZM: 19-000001-984-1 PAGE 3 OF 6

DEFINITIONS 

1. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

2. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

3. “Defendants” shall mean BNYM and Celink. 

4. “You,” “Your,” or “Yourself,” means Third-Party Defendant Paula Grooms Davis, and 

your agents and representatives. 

5. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

6. “Third-Party Defendants” shall mean Jeffrey Ray Grooms, Individually, Paula Grooms 

Davis, and Michael Grooms. 

7. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

8. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

9. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

10. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

11. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 75 of 94 PageID 112
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT PAULA GROOMS 

DAVIS 

MWZM: 19-000001-984-1 PAGE 4 OF 6

12. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

13. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

14. “Or” and “and” mean and/or. 

15. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

REQUESTS FOR ADMISSIONS 

REQUEST NO. 1: Admit that that you are not a party to the Loan. 

RESPONSE: 

REQUEST NO. 2: Admit the full and correct legal name of Ray Grooms is Jalmer Ray Grooms. 

RESPONSE: 

REQUEST NO. 3: Admit the full and correct legal name of Christine Grooms is Evelyn 

Christine Grooms. 

RESPONSE: 

REQUEST NO. 4: Admit the Affidavit of Heirship, recorded in the Official Public Records of 

Tarrant County, Texas at Instrument No. D201272988, contains the sole following real property 

description: 

LOT 19, 20, AND 21, MEADOW PARK ADDITION TO THE 

CITY OF WHITE SETTLEMENT, TARRANT COUNTY, 

TEXAS, ACCORDING TO THE PLAT RECORDED IN 

VOLUME 388-B, PAGE 209, PLAT RECORDS, TARRANT 

COUNTY, TEXAS. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 76 of 94 PageID 113
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT PAULA GROOMS 

DAVIS 

MWZM: 19-000001-984-1 PAGE 5 OF 6

REQUEST NO. 5: Admit that Christine Grooms entered into a Texas Home Equity Conversion 

Loan Agreement with Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B. on January 17, 2006. 

RESPONSE: 

REQUEST NO. 6: Admit Christine Grooms executed the Note on January 17, 2006. 

RESPONSE: 

REQUEST NO. 7: Admit Christine Grooms executed the Deed of Trust on January 17, 2006. 

RESPONSE: 

REQUEST NO. 8: Admit Christine Grooms executed an Adjustable Rate Second Note (Home 

Equity Conversion) on January 17, 2006. 

RESPONSE: 

REQUEST NO. 9: Admit Christine Grooms executed an Adjustable Rate Home Equity 

Conversion Second Deed of Trust on January 17, 2006. 

RESPONSE: 

REQUEST NO. 10: Admit Christine Grooms held herself out to be the sole owner of the 

Property when she entered into the Loan.

RESPONSE: 

REQUEST NO. 11: Admit you knew about the Loan on January 17, 2006. 

RESPONSE: 

REQUEST NO. 12: Admit you consented to the Loan. 

RESPONSE: 

REQUEST NO. 13: Admit you consented to the Lien created by the Deed of Trust. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 77 of 94 PageID 114
DEFENDANTS’ REQUESTS FOR ADMISSIONS TO THIRD-PARTY DEFENDANT PAULA GROOMS 

DAVIS 

MWZM: 19-000001-984-1 PAGE 6 OF 6

REQUEST NO. 14: Admit Christine Grooms died on May 2, 2018.

RESPONSE: 

REQUEST NO. 15: Admit Christine Grooms died without a will and testament. 

RESPONSE: 

REQUEST NO. 16: Admit Defendants advanced funds to pay the ad valorem taxes on the 

Property in the amount of $404.05 on December 20, 2018. 

RESPONSE: 

REQUEST NO. 17: Defendants advanced funds to pay the ad valorem taxes on the Property in 

the amount of $464.96 on December 13, 2019. 

RESPONSE: 

REQUEST NO. 18: Admit Defendants have not foreclosed or sold the Property as of the date of 

your responses hereto. 

RESPONSE: 

REQUEST NO. 19: Admit you have not made any payments under the Loan Agreement. 

RESPONSE: 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 78 of 94 PageID 115
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 1 OF 9

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

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IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

To: Third-Party Defendant Paula Grooms Davis, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant Paula 

Grooms Davis, produce for inspection, copying, or photographing the following described 

documents and/or tangible things. Said production and inspection is to be made at the office of 

Defendants’ attorneys during regular business hours on or before thirty (30) days after service of 

Exhibit M

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 79 of 94 PageID 116
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 2 OF 9

these Requests for Production upon you. In the alternative, you may attach to your Response the 

original or duplicate of the documents and/or tangible things requested. 

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

Case 4:22-cv-00772-O Document 1-8 Filed 08/29/22 Page 80 of 94 PageID 117
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 3 OF 9

DEFINITIONS AND INSTRUCTIONS 

1. The term “documents” is used in the broadest sense of that term and includes the original 

and all non-identical copies, whether different from the original by reason of notations 

made on such copies or otherwise, and all drafts of: letters, telegrams, memoranda, 

reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call 

reports, financial and business records, receipts, contracts, reports, studies, calendar 

entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, 

statistical or informational accumulations, summaries or abstracts, any kind of records of 

meetings or conversations, firm impressions, sound or mechanical reproductions, rules, 

regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, 

publications, instructions, transparencies, handbooks, manuals, operating procedures, 

appointment calendars, call slips, file jackets, course materials, training materials, 

minutes, testimony, photographs, videotapes, films, press releases, speeches, surveys, 

graphs, statistics, tables, printed or typewritten forms, indices, agreements, canceled 

checks, correspondence, memos, telephone message slips, sketches, notes of 

conversations, and all other written, printed, typed or other reported matter, photographs, 

or other data compilations in which information can be obtained, which are in the 

possession, custody, or control of you, your attorneys, agents, physicians, directors, 

officers, partners, affiliates, subsidiaries, servants, or employees. Please note that 

“document” is also used to include documents, information or data on computer storage, 

data on computer disks, data stored on computer backup, electronic mail messages and 

other electronic correspondence, disks, electronic or magnetic recordings, Internet 

transmissions, Intranet transmissions, electronic bulletin boards, websites, diary systems, 

calendar systems, tickler systems and other information stored in, or accessible through 

computers, lap tops, hard drives, disks, or other information storage retrieval systems, 

together with instructions and all other materials necessary to use or interpret such data 

compilations in which information can be obtained, which are in the possession, custody, 

or control of you, your attorneys, agents, physicians, directors, officers, partners, 

affiliates, subsidiaries, servants, or employees. 

2. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

3. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

4. “Defendants” shall mean BNYM and Celink. 

5. “You,” “Your,” or “Yourself,” means Third-Party Defendant Paula Grooms Davis, and 

your agents and representatives. 

6. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

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DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 4 OF 9

7. “Plaintiff” shall mean and refer to Plaintiff/Counter-Defendant Jeffrey Ray Grooms, 

Independent Administrator of the Estate of Evelyn Christine Grooms, Deceased. 

8. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

9. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

10. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

11. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

12. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

13. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

14. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

15. “Or” and “and” mean and/or. 

16. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

17. “Person” or “persons” means not only natural persons, but also corporations, 

partnerships, organizations, associations, industry groups, entities, joint ventures, or any 

government or governmental entity, commission, or agency and any divisions or 

departments or other units of any of the entities defined herein. 

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DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

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MWZM: 19-000001-984-1 PAGE 5 OF 9

18. “Relate” or “relating to” includes referring to, mentioning, reflecting, containing, 

pertaining to, evidencing, involving, describing, discussing, responding to, supporting, 

opposing, constituting or being a draft, copy or summary of, in whole or in part. 

19. You are to supplement or amend the Responses you give to this Request for Production 

as required by the Texas Rules of Civil Procedure. 

20. You are required to produce all documents requested within your possession, custody or 

control. Possession, custody or control includes constructive possession such that the 

person need not have actual physical possession. As long as the person has the superior 

right to compel the production from a third party (including an agency, authority or 

representative), the person has possession, custody or control. 

21. If any document was, but is no longer, in your possession, custody or control, state what 

disposition was made of it, by whom, and the date or dates or approximate date or dates 

on which such disposition was made and why. 

22. If you claim that any document for which production is requested is privileged, and 

therefore beyond the scope of discovery, for each document: 

 

a) Identify the document by specifying the date or approximate date of preparation, 

the nature of its contents, the name of its author, and the name and business 

address of its custodian. 

b) Specify the precise nature of the privilege claimed. 

23. To avoid ambiguity, significant effort has been spent to define a number of terms used in 

the following discovery requests. If you or your attorneys claim you do not understand 

the meaning of a term, please refer to the list of definitions or contact the opposing 

attorney for clarification. 

24. This discovery request is continuing. In the event that any information or material 

responsive to any Request comes to your attention, possession, custody, or control, or the 

attention, possession, custody or control of your agents, employees, affiliates, 

subsidiaries, accountants, partners, officers, family members, directors, or attorneys 

subsequent to the filing of your response, you are required to furnish the additional 

information, answers, or material to the opposing attorney as soon as possible. 

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DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

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MWZM: 19-000001-984-1 PAGE 6 OF 9

REQUESTS FOR PRODUCTION 

REQUEST NO. 1: Produce all documents referenced in any of your responses to the 

Interrogatories from Defendants. 

 RESPONSE: 

REQUEST NO. 2: All documents which relate to the factual allegations in your First 

Amended Complaint, or any subsequent amendment or supplement thereto, including without 

limitation, written or recorded statements. 

 RESPONSE: 

REQUEST NO. 3: Each and every document, including records and emails, 

photographs, slides, pictures, videotapes, audiotapes, or other visual or graphic representations 

you intend to offer at the trial of this cause, including demonstrative exhibits. 

 RESPONSE: 

REQUEST NO. 4: Any and all documents which originated or emanated from BNYM 

and/or Celink, or which you contend would be construed as a document of Defendants that is in 

your possession, your attorney’s possession, or the possession of anyone assisting you in this 

case. 

 RESPONSE: 

REQUEST NO. 5: All documents evidencing or reflecting any communication by and 

between you and BNYM or any representative of BNYM related to the Loan or the Property. 

 RESPONSE: 

REQUEST NO. 6: All documents evidencing or reflecting any communication by and 

between you and Celink or any representative of Celink related to the Loan or the Property. 

 RESPONSE: 

REQUEST NO. 7: All documents evidencing or reflecting any communication by and 

between you and Plaintiff related to the Loan or the Property. 

 RESPONSE: 

 

REQUEST NO. 8: All documents, checks, coupons, or other financial statements, 

reflecting or evidencing the date, time, and/or amount of any or all payments made for ad 

valorem taxes on the Property from January 17, 2006 to date. 

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DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

DEFENDANT PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 7 OF 9

 RESPONSE: 

REQUEST NO. 9: With regard to all testifying experts that you intend to use in this 

case, all documents, tangible things, reports, models, or data compilations that have been 

provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s 

testimony. 

 RESPONSE: 

REQUEST NO. 10: With regard to all testifying experts that you intend to use in this 

case, the expert’s current resume, curriculum vitae, and/or bibliography. 

 RESPONSE: 

REQUEST NO. 11: Produce all information, materials, data compilations or documents 

reviewed or relied on in whole or in part by each expert whom you may call to testify at trial. 

 RESPONSE: 

REQUEST NO. 12: All the trial exhibits that you intend to use in this case. 

 RESPONSE: 

REQUEST NO. 13: All documents evidencing any alleged wrongdoing that you 

contend that BNYM and/or Celink engaged in. 

 RESPONSE: 

REQUEST NO. 14: All documents relating to or substantiating your claims for 

monetary damages. 

 RESPONSE: 

REQUEST NO. 15: All documents that constitute, evidence, refer or relate to any 

agreement or plan, whether oral or written, concerning any contingency fee arrangement and/or 

the payment of attorney fees in connection with this case. 

 RESPONSE: 

REQUEST NO. 16: All time records, including contemporaneous time sheets setting 

forth descriptions of the work performed on this case for which you or your attorneys will seek 

attorneys’ fees. 

 RESPONSE: 

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DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

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REQUEST NO. 17: All documents evidencing or reflecting any communication by and 

between you and Plaintiff related to the Affidavit of Heirship. 

 RESPONSE: 

REQUEST NO. 18: All documents that evidence, refer, or relate to any foreclosure 

proceeding against any Estate property, other than the subject Property at 801 Ala Drive, 

including any foreclosure proceeding that was threatened and/or anticipated but did not take 

place. 

 RESPONSE: 

REQUEST NO. 19: All documents that evidence, refer, or relate to real property owned 

in whole or in part by Jalmer Ray Grooms prior to his death, other than the subject Property at 

801 Ala Drive. 

 RESPONSE: 

REQUEST NO. 20: All documents that evidence, refer, or relate to real property owned 

in whole or in part by Evelyn Christine Grooms prior to her death, subject Property at 801 Ala 

Drive. 

 RESPONSE: 

REQUEST NO. 21: All notices of default, acceleration, or foreclosure that you received 

concerning the Property or Loan. 

 RESPONSE: 

REQUEST NO. 22: All documents reflecting the payment, in whole or in part, of any 

debts, whether secured or unsecured, specifically from the proceeds of the Loan. 

 RESPONSE: 

REQUEST NO. 23: If any funds/proceeds from the Loan were used to make repairs, 

changes, or improvements to the Property, produce all documents, checks, receipts, or other 

documentation reflecting same. 

 RESPONSE: 

REQUEST NO. 24: Any and all documents tending to support your claim the original 

lender on the Loan, Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., had knowledge or was aware of Plaintiff’s alleged interest in the Property as of 

January 17, 2006. 

 RESPONSE: 

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DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO THIRD-PARTY 

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REQUEST NO. 25: Any and all documents tending to support your claim Defendants 

had knowledge or were aware of Plaintiff’s or Third-Party Defendants’ alleged interest in the 

Property prior to the death of Evelyn Christine Grooms. 

 RESPONSE: 

 REQUEST NO. 26: All documents that support your claim that “Defendants continue to 

make demands for payment despite not responding to the February 19, 2019 dispute.” 

 RESPONSE: 

 REQUEST NO. 27: All documents that support your claim that not all owners of the 

Property and their spouses consented to the Deed of Trust lien. 

 RESPONSE: 

 REQUEST NO. 28: All documents that support your claim that Defendants intended to 

abuse you or cause a serious upset of your daily life. 

 RESPONSE: 

 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 1 OF 7

CAUSE NO. 2018-PR02471-1-A 

JEFFREY RAY GROOMS, Independent 

Administrator the Estate of Evelyn 

Christine Grooms, Deceased, 

Plaintiff / Counter-Defendant, 

v. 

THE BANK OF NEW YORK MELLON 

TRUST COMPANY, N.A., AS TRUSTEE 

FOR MORTGAGE ASSETS 

MANAGEMENT SERIES I TRUST, and 

COMPU-LINK CORPORATION dba 

CELINK, 

Defendants / Counter-Plaintiffs / 

Third-Party Plaintiffs, 

v. 

JEFFREY RAY GROOMS, Individually, 

PAULA GROOMS DAVIS, and 

MICHAEL GROOMS, 

Third-Party Defendants. 

§

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§

IN THE PROBATE COURT

NO. 1

TARRANT COUNTY, TEXAS

DEFENDANTS’ FIRST INTERROGATORIES TO 

THIRD-PARTY DEFENDANT PAULA GROOMS DAVIS 

To: Third-Party Defendant Paula Grooms Davis, c/o Jerry J. Jarzombek, 

jerryjj@airmail.net, 6300 Ridglea Place, Suite 610, Ft. Worth, TX 76116. 

Defendants/Counter-Plaintiffs/Third-Party Plaintiffs The Bank of New York Mellon 

Trust Company, N.A. as Trustee for Mortgage Assets Management Series I Trust, and CompuLink Corporation d/b/a Celink (“Defendants”) hereby request that Third-Party Defendant Paula 

Grooms Davis, answer in writing and under oath the following set of Interrogatories within thirty 

(30) days from the date of service hereof. 

Exhibit N

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 2 OF 7

Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, P.C. 

14160 North Dallas Parkway, Suite 900 

Dallas, Texas 75254 

Telephone: 214-635-2650 

Facsimile: 214-635-2686 

Attorneys for Defendants/Counter-Plaintiffs/ 

Third-Party Plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has been served 

via electronic service on January 11, 2021 on the following counsel of record: 

 

 JoAnn H. Means 

joann@pulshaney.com 

PULS HANEY LYSTER PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

Jerry J. Jarzombek 

jerryjj@airmail.net 

The Law Office of Jerry Jarzombek, PLLC 

6300 Ridglea Place, Suite 610 

Fort Worth, TX 76116 

Counsel for Plaintiff/Counter-Defendant/Third-Party Defendants 

 /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

PAULA GROOMS DAVIS 

MWZM: 19-000001-984-1 PAGE 3 OF 7

DEFINITIONS AND INSTRUCTIONS 

1. The term “documents” is used in the broadest sense of that term and includes the original 

and all non-identical copies, whether different from the original by reason of notations 

made on such copies or otherwise, and all drafts of: letters, telegrams, memoranda, 

reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call 

reports, financial and business records, receipts, contracts, reports, studies, calendar 

entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, 

statistical or informational accumulations, summaries or abstracts, any kind of records of 

meetings or conversations, firm impressions, sound or mechanical reproductions, rules, 

regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, 

publications, instructions, transparencies, handbooks, manuals, operating procedures, 

appointment calendars, call slips, file jackets, course materials, training materials, 

minutes, testimony, photographs, videotapes, films, press releases, speeches, surveys, 

graphs, statistics, tables, printed or typewritten forms, indices, agreements, canceled 

checks, correspondence, memos, telephone message slips, sketches, notes of 

conversations, and all other written, printed, typed or other reported matter, photographs, 

or other data compilations in which information can be obtained, which are in the 

possession, custody, or control of you, your attorneys, agents, physicians, directors, 

officers, partners, affiliates, subsidiaries, servants, or employees. Please note that 

“document” is also used to include documents, information or data on computer storage, 

data on computer disks, data stored on computer backup, electronic mail messages and 

other electronic correspondence, disks, electronic or magnetic recordings, Internet 

transmissions, Intranet transmissions, electronic bulletin boards, websites, diary systems, 

calendar systems, tickler systems and other information stored in, or accessible through 

computers, lap tops, hard drives, disks, or other information storage retrieval systems, 

together with instructions and all other materials necessary to use or interpret such data 

compilations in which information can be obtained, which are in the possession, custody, 

or control of you, your attorneys, agents, physicians, directors, officers, partners, 

affiliates, subsidiaries, servants, or employees. 

2. “BNYM” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff The Bank of New 

York Mellon Trust Company, N.A. as Trustee for Mortgage Assets Management Series I 

Trust. 

3. “Celink” shall mean Defendant/Counter-Plaintiff/Third-Party Plaintiff Compu-Link 

Corporation d/b/a Celink, 

4. “Defendants” shall mean BNYM and Celink. 

5. “You,” “Your,” or “Yourself,” means Third-Party Defendant Paula Grooms Davis, and 

your agents and representatives. 

6. The “Estate” means the Estate of Evelyn Christine Grooms, Deceased. 

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MWZM: 19-000001-984-1 PAGE 4 OF 7

7. “Plaintiff” shall mean and refer to Plaintiff/Counter-Defendant Jeffrey Ray Grooms, 

Independent Administrator of the Estate of Evelyn Christine Grooms, Deceased. 

8. “Communication” shall mean and refer to any mode of communication, including but not 

limited to conversations, correspondence, telephone conversations, facsimiles, and e-mail 

or other electronic communications. 

9. “House” and “Property” shall mean and refer to the real property and residence located at 

801 Ala Drive, White Settlement, Texas 76108 and more particularly described as: 

LOT 11 AND THE NORTH 12 FEET OF LOT 10, BLOCK 13 OF

MCDONNELL ADDITION TO THE CITY OF WHITE 

SETTLEMENT, TARRANT COUNTY, TEXAS, ACCORDING 

TO PLAT RECORDED IN VOLUME 388-11, PAGE 29, PLAT 

RECORDS, TARRANT COUNTY, TEXAS. 

10. “Loan Agreement” shall mean and refer to that certain Texas Home Equity Conversion 

Loan Agreement signed by Christine Grooms with Financial Freedom Senior Funding 

Corporation, a Subsidiary of IndyMac Bank, F.S.B. on January 17, 2006. 

11. “Note” shall mean and refer to the Adjustable Rate Note (Home Equity Conversion)

signed by Christine Grooms in the original principal amount of up to a maximum of 

$133,500.00 payable to Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. and bearing interest at the rate of 5.8700% per annum. 

12. “Deed of Trust” shall mean and refer to the Adjustable Rate Home Equity Conversion 

Deed of Trust signed by Christine Grooms, as grantor, granting a security interest in the 

Property to Financial Freedom Senior Funding Corporation, a Subsidiary of IndyMac 

Bank, F.S.B., its successors and assigns, recorded in the Official Public Records of 

Tarrant County, Texas under Instrument No. D206032197. 

13. The “Loan” shall mean and refer collectively to the Loan Agreement, Note, Deed of 

Trust, and money borrowed by Christine Grooms pursuant to such documents. 

14. “Affidavit of Heirship” shall mean and refer to the Affidavit of Heirship recorded in the 

Official Public Records of Tarrant County, Texas at Instrument No. D201272988 

15. “Or” and “and” mean and/or. 

16. The singular shall include the plural, and the plural the singular, whenever the effect of 

doing so is to increase the information responsive to the request for information. 

17. “Person” or “persons” means not only natural persons, but also corporations, 

partnerships, organizations, associations, industry groups, entities, joint ventures, or any 

government or governmental entity, commission, or agency and any divisions or 

departments or other units of any of the entities defined herein. 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

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18. “Relate” or “relating to” includes referring to, mentioning, reflecting, containing, 

pertaining to, evidencing, involving, describing, discussing, responding to, supporting, 

opposing, constituting or being a draft, copy or summary of, in whole or in part. 

19. As to any Interrogatory that you refuse to answer or are unable to answer in whole or in 

part, for any reason, please state the grounds for your refusal or inability to answer. 

When you believe that a complete answer to a particular Interrogatory or part thereof is 

not possible, please answer each Interrogatory to the extent possible and furnish a 

statement explaining: (a) the reason for your inability to answer further; and (b) whatever 

information or knowledge you have concerning the unanswered portion. 

20. Furnish all information available to you and known by you, or in your possession, care, 

custody or control, or possession, care, custody, or control of your agents and/or 

attorneys, or appearing in your records. 

21. You shall supplement your answers or other responses to these Interrogatories. 

22. Should you exercise your option to produce business records in response to an 

Interrogatory, you shall specify with particularity the location and identity of the business 

records where the information requested is found. Such production of documents does 

not satisfy the obligation to answer an Interrogatory if information within the scope of the 

Interrogatory other than that contained in the documents is available to you. 

23. You shall quote each Interrogatory in full immediately preceding the corresponding 

response. Each answer, objection, or response to the Interrogatories shall be identified by 

the same number and subpart of the corresponding Interrogatory and shall appear in the 

same order as the corresponding Interrogatory. Subparts of each Interrogatory shall be 

answered separately to avoid overlooking part of the question. 

24. If a document responsive to any Interrogatory has been lost, mutilated, or destroyed, so 

state and identify each such document, and state to which Interrogatory(ies) the document 

would have been responsive. 

25. The definitions listed above are to be construed as broadly as possible to include the most 

information or documents responsive to the discovery requests propounded herein. 

26. To avoid ambiguity, significant effort has been spent to define a number of terms used in 

the following discovery requests. If you or your attorneys claim you do not understand 

the meaning of a term, please refer to the list of definitions or contact the opposing 

attorney for clarification. 

27. This discovery request is continuing. In the event that any information or material 

responsive to any Interrogatory or request for production comes to your attention, 

possession, custody, or control, or the attention, possession, custody or control of your 

agents, employees, affiliates, subsidiaries, accountants, partners, officers, family 

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DEFENDANTS’ FIRST INTERROGATORIES TO THIRD-PARTY DEFENDANT 

PAULA GROOMS DAVIS 

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members, directors, or attorneys subsequent to the filing of your response, you are 

required to furnish the additional information, answers, or material to the opposing 

attorney as soon as possible. 

INTERROGATORIES 

INTERROGATORY NO. 1: State the name and address of all persons whom you know or 

believe to have personal knowledge or discoverable information, factual information, documents, 

photographs or audio or visual information pertaining to any fact that relates in any way to any 

issue in this case, including those persons who may have impeaching information. For each such 

person, describe the subject or topic of the person’s knowledge and identify whether you will call 

this person as a witness at trial. 

ANSWER: 

INTERROGATORY NO. 2: Identify all persons you may or will call as a witness at the trial 

of this case including their current address, phone number and place of employment. 

ANSWER: 

INTERROGATORY NO. 3: List each and every instance when you, or someone acting on 

your behalf, contacted, whether by phone, email or other written correspondence BNYM or 

Celink regarding the issues which are the subject of this suit and, for each instance, state the date 

of such contact, who made the contact on behalf; the representative who was contacted, the 

identity of all persons present or with knowledge of each communication and the substance of 

any such contact or communication. 

ANSWER: 

INTERROGATORY NO. 4: Please list each and every instance when BNYM, Celink, or 

someone acting on their behalf, contacted you in any manner regarding the issues which are the 

subject of this suit and, for each instance, state the date of such contact, the representative who 

made the contact and the substance of any such communication. 

ANSWER: 

INTERROGATORY NO. 5: Identify each and every real property parcel, by street address and 

legal description, in which you have or had any partial or whole ownership interest from 

February 8, 2001 to date, including the dates when the ownership interest began and when it 

terminated, of applicable. 

ANSWER: 

INTERROGATORY NO. 6: Identify the date you first learned Christine Grooms took out the 

Loan, including in your answer the manner by which you discovered the existence of the Loan. 

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ANSWER: 

INTERROGATORY NO. 7: Identify the date of and manner by which you first learned you 

may have an ownership interest in the Property. 

ANSWER: 

INTERROGATORY NO. 8: If you were married on January 17, 2006, identify your spouse 

and the dates of the marriage. 

ANSWER: 

INTERROGATORY NO. 9: Identify each and every instance when you, or someone acting on 

your behalf, communicated with Financial Freedom Senior Funding Corporation, a Subsidiary of 

IndyMac Bank, F.S.B. regarding the Loan or the Property and, for each instance, state the date of 

such contact, who made the contact on behalf; the representative who was contacted, the identity 

of all persons present or with knowledge of each communication and the substance of any such 

contact or communication

ANSWER: 

INTERROGATORY NO. 10: Identify each and every instance when you, or someone acting

on your behalf, communicated with Edward Scoular, P.E. or Independent Foundation Engineers, 

Inc. regarding the Property and, for each instance, state the date of such contact, who made the 

contact on behalf; the representative who was contacted, the identity of all persons present or 

with knowledge of each communication and the substance of any such contact or 

communication. 

ANSWER: 

INTERROGATORY NO. 11: Identify each and every instance when you, or someone acting

on your behalf, communicated with a contractor regarding repairs for the Property and, for each 

instance, identify the contractor, state the date of such contact, who made the contact on behalf; 

the representative who was contacted, the identity of all persons present or with knowledge of 

each communication and the substance of any such contact or communication 

ANSWER: 

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