Depose for foreclosure case-not first hand knowledge

[gillisrp01]

My State: Florida Affiant in: North Carolina
My question is in regard to a Florida Foreclosure, and my desire to depose an Affiant in North Carolina. I am being sued for foreclosure by Bank #2, but an official from Bank #1 is swearing to the amount that I owe. Also another fact about this case is this is the third affidavit of this kind being filed by the bank in this case. The first one was blank and submitted that way, and the bank asked for a summary judgment hearing about the affidavit, and got in trouble with the judge since the form submitted was blank. The second and now the third affidavit of this kind have been submitted, but no court hearing on the issue so far. Also, the bank cannot find mortgage and note (after starting this case in January 2008 (YES, 16 months ago) so my contention is this person doesn't work for Bank #2 who claims to own but can't find the mortgage & note, AND how could they have first hand knowledge anyway as they just pull numbers from computer - that is NOT first-hand knowledge as required. An attorney said I should go to NC and depose her, but didn't say what steps, or exactly what questions I need to ask to get the required information about the lack of valid information. All help will be appreciated.