UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA
AT BECKLEY
CASE NO. 5:24-cv-00700
ANNA WHITE FERRARACCIO
Plaintiff
v.
NEW PEOPLE’s BANK
Defendant
/
FIRST SET OF INTERROGATORIES TO DEFENDANT
Plaintiff, by and through her undersigned counsel, gives notice of serving her First Set of Interrogatories to Defendant which are to be answered in writing, under oath, within thirty (30) days.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been emailed this 14 day of November 2025 : Counsel of Record.
Behren Law Firm
1930 N. Commerce Parkway-Suite 4
Weston, FL 33326
(954) 636-3802 – phone
(772) 252-3365 – fax
scott@behrenlaw.com
By:/Scott M. Behren/
Scott M. Behren
Fla Bar No. 987786
DEFINITIONS AND INSTRUCTIONS
1. The term “you” or “your” means the party or parties to whom these Interrogatories are addressed, including its divisions, departments, subsidiaries, affiliates, predecessors, and all other persons acting or purporting to act on its behalf, as well as each partnership in which it is a partner.
2. The term “person” means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons or other entity.
3. The term “document” means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, interoffice and intraoffice telephone calls, diaries, chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, charts, ledgers, invoices, work-sheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or aural records or representations of any kind (including micro-film, videotape, recordings, motion pictures) and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and records).
4. The term “all documents” means every document or group of documents or communication as above defined that are known to you or that can be located or discovered by reasonably diligent efforts.
5. As used herein the singular shall include the plural, the plural shall include the singular, and the masculine, feminine, and neuter shall include each of the other genders.
6. If all the information furnished in answer to all or part of an Interrogatory is not within the personal knowledge of the affiant, identify each person to whom all or part of the information furnished is a matter of personal knowledge and each person who communicated to the affiant any part of the information furnished.
7. If the answer to all or any part of the Interrogatory is not presently known or available, include a statement to that effect, furnish the information known or available, and respond to the entire Interrogatory by supplemental answer, in writing, under oath, within ten days from the time the entire answer becomes known or available, and in no event, less than five days prior to trial.
8. Whenever, in any answer to any Interrogatory, a reference is made to one or more persons, specify by name the particular person to whom reference is intended.
INTERROGATORIES
1. State the name, social security number, home address, business address, home telephone number and business telephone number of each person answering all or any one of these Interrogatories.
2. State the names, social security numbers (if known), home addresses, business addresses, home telephone numbers and business telephone numbers of any and all witnesses with knowledge or information relevant to the subject matter of this action.
3. With regard to each such individual identified in Interrogatory No. 2 above, state, with specificity, the nature and substance of such knowledge possessed, or believed to be possessed, by each such person.
4. Identify the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature which concerns or relates to the subject matter of this action.
5. State the name, home address, business address, home telephone number and business telephone number of each expert witness engaged by you in this action, for any purpose.
6. State the substance of the opinion of each such expert witness engaged by you which you have identified in Interrogatory No. 5 above.
7. List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised by the pleadings and specify the subject matter about which the witness has knowledge.
8. Have you ever been convicted of crime? If so, what was the date and place of conviction.
9. Please set forth with specificity the factual basis for each affirmative defense that you have alleged or intend to allege in response to Plaintiff’s Second Amended
Complaint.
10. Set forth with specificity each and every non judicial foreclosure that you proceeded with, since January 1, 2015. For each identify the customer, type of loans,
property foreclosed upon, loan numbers, dates of foreclosure and identify all relevant documents for these foreclosures.
_________________________
NEW PEOPLE’s BANK
By:__________________________
Its:__________________________
COUNTY OF )
: ss.
STATE OF )
Before me, the undersigned authority, personally appeared ________, which, being first duly sworn, deposed and said that the foregoing Answers to Interrogatories are true and correct based upon his/her own personal knowledge.
Notary Public, State of
Print, Type or Stamp Name of Notary Public
Personally known ____ or
Type of identification produced _______________
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA
AT BECKLEY
CASE NO. 5:24-cv-00700
ANNA WHITE FERRARACCIO
Plaintiff
v.
NEW PEOPLE’s BANK
Defendant
/
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT
Plaintiff, by and through her undersigned counsel, hereby requests that Defendant, produce all materials requested herein at the offices of the undersigned counsel within thirty (30) days from the date hereof, or such shorter time as may be ordered by the Court, pursuant to Federal Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been emailed this 14 day of November 2025 : Counsel of Record.
Behren Law Firm
1930 N. Commerce Parkway-Suite 4
Weston, FL 33326
(954) 636-3802 – phone
(772) 252-3365 – fax
scott@behrenlaw.com
By:/Scott M. Behren/
Scott M. Behren
Fla Bar No. 987786
DEFINITIONS AND INSTRUCTIONS
1. This request for production is directed to all documents in your possession or control, or in the possession or control of your agents, attorneys, accountants, or other representatives.
2. In the event that you seek to withhold production of any documents(s) on the basis of a claim of privilege, identify separately each such document by its date, description, author, recipient and number of pages and explain the basis on which you assert a privilege.
3. In accordance with Rule 1.350(b) of the Florida Rules of Civil Procedure, you are additionally requested to file a written response to these requests for production and identify the documents and things which you produce in accordance with the categories set out in this request.
4. The term “person” includes any natural person, firm, partnership, joint venture, corporation, or group of natural persons or such entities.
5. The term “document(s)” is intended to be comprehensive and to include, without limitation, all original writings of any nature whatsoever, copies and drafts which, by reason of notes, changes, initials, or identification marks are not identical to the originals. In all cases where the original and/or copies or drafts are not available, documents also means a copy thereof.
6. The term “document(s)” means any tangible thing from or on which information can be stored, recorded, processed, transmitted, inscribed, or memorialized in any way by and means, regardless of technology or form and including, but not being limited to: papers, books, accounts, newspapers and magazine articles, letters, photographs, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, transcripts, minutes, reports and recordings of telephone or other conversation, or of interviews of conferences, or of other meetings, occurrences, or transactions, affidavits, transcripts of depositions or hearings, statements, summaries, opinions, reports, tests, experiments, analyses, evaluations, contracts, agreements, ledgers, journals, books or records of account, receipts, summaries of accounts, balance sheets, income statements, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound recordings, computer printouts, data processing input and output, mechanical means, and things similar to any of the foregoing however, denominated. Each copy of a document which contains any separate notations or writings thereon shall be deemed to be a separate document for purposes of these discovery requests.
7. In the event that any document called for herein has been destroyed, that document is to be identified as follows: author, addressor, addressee, recipients of indicated or “blind” copies, date, subject matter, number of pages, attachments or appendices, all persons believed at any time to have had a copy of the document, date of destruction, place and manner of destruction, persons authorizing destruction and person destroying the document.
DOCUMENTS REQUESTED
1. Any and all communications, written or electronic, between any agent or employee of Defendant and Plaintiff since January 2000.
2. Any and all communications or correspondence, written or electronic, between any employees or agents of Defendant, and relating to Plaintiff since January 2000.
3. All documents you intend to use as exhibits at trial of this matter.
4. All statements of third parties taken who have knowledge of the allegations raised in the Second Amended Complaint or in your Answer and Affirmative Defenses.
5. All expert reports obtained from any expert that you intend to use at trial of this matter.
6. All loan documents between you and Plaintiff and any of her corporations.
7. Your entire loan files for each of Plaintiff or her companies loans with you.
8. All documents showing all payments from you to Plaintiff or any of her companies since January 2000.
9. All documents showing all payments from Plaintiff or any of her companies to you since January 2000.
10. All documents relating to any non judicial foreclosures for any properties of Plaintiff or her companies.
11. All default notices sent by you to Plaintiff or any of her corporations at any time.
12. All computer or system notes showing any interactions or conversations with Plaintiff or any of her companies since January 2000.
13. Your entire loan files for all non-judicial foreclosures handled by you as identified in your answers to interrogatories.
14. All documents identifying all potential buyers of property of the Plaintiff and her corporations as suggested by William Winfrey on or about March 16, 2025.
15. All notices sent at any time to Plaintiff or her corporations of any non-judicial foreclosures started by you since January 1, 2000.
16. All communications between you and/or William Winfrey and Joseph Angotti or Grouse Ridge Capital.
17. All of your internal guidelines and/or policies and procedures to be followed in handling non judicial foreclosures since January 1, 2000.
18. All documents you plan on using at the trial of this matter.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA
AT BECKLEY
CASE NO. 5:24-cv-00700
ANNA WHITE FERRARACCIO
Plaintiff
v.
NEW PEOPLE’s BANK
Defendant
/
PLAINTIFF’S SECOND REQUEST FOR PRODUCTION TO DEFENDANT
Plaintiff, by and through her undersigned counsel, hereby requests that Defendant, produce all materials requested herein at the offices of the undersigned counsel within thirty (30) days from the date hereof, or such shorter time as may be ordered by the Court, pursuant to Federal Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been emailed this 17 day of November 2025 : Counsel of Record.
Behren Law Firm
1930 N. Commerce Parkway-Suite 4
Weston, FL 33326
(954) 636-3802 – phone
(772) 252-3365 – fax
scott@behrenlaw.com
By:/Scott M. Behren/
Scott M. Behren
Fla Bar No. 987786
DEFINITIONS AND INSTRUCTIONS
1. This request for production is directed to all documents in your possession or control, or in the possession or control of your agents, attorneys, accountants, or other representatives.
2. In the event that you seek to withhold production of any documents(s) on the basis of a claim of privilege, identify separately each such document by its date,
description, author, recipient and number of pages and explain the basis on which you assert a privilege.
3. In accordance with Rule 1.350(b) of the Florida Rules of Civil Procedure, you are additionally requested to file a written response to these requests for production and identify the documents and things which you produce in accordance with the categories set out in this request.
4. The term “person” includes any natural person, firm, partnership, joint venture, corporation, or group of natural persons or such entities.
5. The term “document(s)” is intended to be comprehensive and to include, without limitation, all original writings of any nature whatsoever, copies and drafts which, by reason of notes, changes, initials, or identification marks are not identical to the originals. In all cases where the original and/or copies or drafts are not available, documents also means a copy thereof.
6. The term “document(s)” means any tangible thing from or on which information can be stored, recorded, processed, transmitted, inscribed, or memorialized in any way by and means, regardless of technology or form and including, but not being limited to: papers, books, accounts, newspapers and magazine articles, letters, photographs, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, transcripts, minutes, reports and recordings of telephone or other conversation, or of interviews of conferences, or of other meetings, occurrences, or transactions, affidavits, transcripts of depositions or hearings, statements, summaries, opinions, reports, tests, experiments, analyses, evaluations, contracts, agreements, ledgers, journals, books or records of account, receipts, summaries of accounts, balance sheets, income statements, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound recordings, computer printouts, data processing input and output, mechanical means, and things similar to any of the foregoing however, denominated. Each copy of a document which contains any separate notations or writings thereon shall be deemed to be a separate document for purposes of these discovery requests.
7. In the event that any document called for herein has been destroyed, that document is to be identified as follows: author, addressor, addressee, recipients of indicated or “blind” copies, date, subject matter, number of pages, attachments or appendices, all persons believed at any time to have had a copy of the document, date of destruction, place and manner of destruction, persons authorizing destruction and person destroying the document.
DOCUMENTS REQUESTED
1. All videos or incident reports of each visit to one of your branches or offices since January 2020.