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About combingwyoming

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  1. @BTO429 What are the differences between the motions you recommended, which one do you recommend I file first and how do I file it? I want to hit them hard and fast! I'm sick of being reactive and would like to stick it to them proactively. In the American bar association rule 3.4 that you referenced, were their any responses that the plaintiffs used that obviously violates those rules? I'm not seeing any clear violations. Thank you so much for your amazing help! CombingWyoming
  2. Thank you @racecar very much. What should I do moving forward? Should I try to compel them to answer each of my discovery questions? How do I now express to the judge that they have nothing? How do I put them on the defensive and force them to walk away with their tail between their legs?
  3. Hello again friends! I recently received the plaintiffs response to my interrogatories, RFP and RFA (below). I am being sued by a JDB for approximately 10k. I have several questions: 1) what do I need to file to force the plaintiff to answer my discovery? 2) after reading their responses below, how do you suggest I force them to answer my discovery? 3) the plaintiff originally sent me an affidavit to prove I owed debt to an Original creditor with an exhibit A that included a excel type print-out of the name of the OC, the principal, interest and total amount owed. Later they amended that affi
  4. I am ready to send off these responses for their discovery. Please let me know what your thoughts are with these responses to RFA. Please comment. Thank you so much!! DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUEST FOR ADMISSIONS 1) Please admit that you have a PO Box number XXXXX in XXXXX, Wyoming. Defendant’s response: Admit 2) Please admit that you received XXXXX credit card statements at PO Box XXXXX in XXXXX, Wyoming. Defendant’s response: Deny 3) Please admit that you had a XXXXX credit card account number XXXX – XXXX – XXXX – XXXX or that you were an authorized user on this ca
  5. Thank you @BTO429, @HotWheels96, @racecar, and @BV80 so much for your help! Below is what I have so far. Please let me know what you think, if there is anything that needs to go, should be added or modified and if you have any ideas on how I answer the RFA. Thank you, I could not do any of this without you! Defendant’s response to Plaintiff’s interrogatories, requests for production of documents, and requests for admissions Comes now Defendant, by and pursuant to WRCPCC 8 and 31, WRCP 36 and the courts oral case management conference ruling, hereby responds to Plaintiff’s interrogato
  6. Hello everyone, I have so much respect and appreciation for this forum of friends who are trying to take on the big JDB's and lawyers, and get justice. I have been reading so many of the topics and learned so much in the last month + of reading all of the great stories and ideas. I need some help! I was sued for $10,000 by a JDB. I responded to the complaint and had a pre-trial telephone conference with the judge and plaintiffs attorney. I would like to fight this as hard as I can. Below are the discovery questions that I was served by the plaintiff and I really need ideas and legalese for
  7. Racecar - Exhibit # 5 is a new and more detailed excel printout that the plaintiffs attorney sent my wife that includes personal information such as her ss #, address and phone number. It also includes the JDB purchase lot #, a bank account number, the name of the OC, a balance, the date the account was opened, the date the account was charged off, the amount that was paid all types of other id #'s etc. I am not sure how to proceed at this point with filing my answers to their requests for admissions, requests for documents and interrogatories because I read and re-read the Wyoming Rules of
  8. Racecar, Below are the RFA they sent me. I will try to type the rogs and RFD later this evening. Any suggestions of how I should respond to each of the below RFA? 1. Please admit that you have an address XXXX in XXXX, WY. 2. Please admit that you received credit card statements from XXXX (OC) to above address 3. Please admit that your credit card number was XXXX and that you were an authorized user of this card 4. Please admit that your SS number ends in XXXX 5. Please admit that you never disputed any credit card charges in writing or otherwise 6. Please see exhibit # 5 (which shows infor
  9. Thank you Anon. In our pre-trial conference, the judge set dates by when discovery must be concluded. They mailed me interrogatories, RFD's and RFA's a week after the date passed. How can I screw them for that?
  10. So heres an update: I served the plaintiff my rogs, RFD's and RFA's before the deadline set in my pre-trial conference. The plaintiff served me with rogs, RFD's and RFA's a week after the deadline set by the judge at the pre-trial conference. They didnt respond yet to my discovery and I didnt respond yet to theirs. Can I use this to my advantage to: 1. Get my case dismissed (lol)? 2. File something with the court to not be required to answer their discovery requests? 3. Give the plaintiff a run for his money? Any guidance, advice or suggestions with examples would be a huge help. Als
  11. Thank you Anon Amos. I have seen it done both ways. Whats the advantage of only sending in a small amount of requests at a time vs. sending them all in at once (so I can have some peace and quiet for a little while )? What do you recommend as the five most important RFPD's to start with? Thank you, CombingWyoming
  12. Thank you shellieh very much for your help, I cant tell you how much I appreciate it! How could I find out if the 30 interrogatories also includes or doesnt include the "requests for admission" and "requests for production"? The Wyoming Rules of Civil Procedure only includes a number (30) of allowed requests by the subject of "interrogatories" but no reference to any allowed number of requests in its subject on "requests for production" and "requests for admission"...?! If someone can google Wyoming Rules of Civil Procedure and let me know what I am missing, that would be a huge help. I rig
  13. Thank you racecar for taking the time to share with me these great resources! I perused through the website you suggested and found lots of great material but there is so much more I can learn, its freaken endless! I have a couple of questions: 1. I have up to 30 interrogatories. What are the musts to include (and why)? 2. I am certain that my affidavits were robo-signed, should I hit them for that in my interrogatories or should I file some other paper for that? Any suggested legalese? Thanks so much, CombingWyoming