DJH715

Thanks Shelli, BV and CN for all your help! I will let everyone know how this goes. I'm hoping when I send my answers and my Discovery that they will realize that I'm going to fight them and they will just not answer my discovery. When they don't answer after 30 days I will send a certified letter asking them to answer and if after 30 days they don't answer still I will file a motion to dismiss with prejudice for lack of evidence. Crossing fingers!

Discovery and Production of Documents Web.pdf Here are my Discovery questions and request for Documents that I have come up with so far. I have 10 Interrogatories and 9 Request for Documents. I need help I want to have alot more so its not easy for them. I've attached what I have so far. Any help would be greatly appreciated on what else I can ask for. Thanks all for what you've done. I can request up to 35 of each.

Answer to Interrogatories Website .pdfShelli and BV I've finished typing up my answers to the Interrogatories and Request for Documents. I'm going to try and upload the pdf file. Please let me know if everything looks good or if I need to change something.

Thanks BV I will do that. I want to show that they have nothing that establishes I have a debt with them.

In August 2010 when I received the first collection letter from the attorney's office for their client PRA, I had no clue who this company was. They didn't even reference anything about GE Money Bank or Walmart or any account number, etc. only PRA and I supposedly owed $38XX to them. I had never heard of this company who is now asking me for $38XX. I wrote a DV letter right away and sent it CMRRR asking who they were and that I wanted copies of any documentation of what debt was owed to them, and how this amount was calculated and proof of ownership. I received a letter back only stating the original creditor was GE Money Bank - Walmart card and an address. Nothing else and still no account number. I wrote back again asking for validation again and referenced my original DV letter and once again asked for more proof which I sent CMRRR. Received nothing and then served with petition the next month by sheriff. Every year since in February, I receive a collection letter stating if I'm due a tax refund to call and try to settle my account with them. They continue to computer call my home trying to collect for the past 3 years. Prior to August 2010 I had not received one document from Precision Analytics and I'm wondering if the attorney's office (who is nationwide) doesn't in fact own the JDB. They have never given me any documents. The only thing I get from them are collection letters and now the Discovery/Documentation request.

Sure BV80 Petition on Suit on Open Account The petition of Precision Recovery Analytics, Inc. organized and doing business under the laws of the State of Texas shows: 1. [Name], and individual of the full age of majority, domiciled in the City of Slidell, State of Louisiana, is indebted unto Prescision Recovery Analytics, Inc. for the amount of $3,887.67 plus attorneys fees, interest, and the cost of these proceedings as more particularly set forth herein. 2. [Name] entered into an agreement with PRA (i'll abbreviate from now on) or its assignor whereby defendant was/were granted the right to obtain goods or services on open account through the use of a credit card. The original creditor is GE Money Bank Walmart Card. The agreement between the parties was further perfected by use of the credit card issued to defendant. 3. [Name] personally or through his or her authorized representative subsequently contracted for sales on open account and acquired goods and services on open account. 4. [Name] breached the Agreement by failing to make payments due on the Account pursuant to the terms of the Agreement. 5. PRA has met all requisites of LRS 9:2781 and the contract between the parties and is due attorney's fees for the prosecution and collection of this claim. Its is respectfully submitted that 25% is a minimum reasonable attorney's fee. 6. After all payments or credits the balance due, notwithstanding amicable demand is $3,887.67. Wherefore petitioner prays for Judgment herein in favor of PRA and against defendant [Name] in the full sum of $3,887.67 plus legal interest from date of judicial demand, a minimum of 25% attorney's fees on the aggregate of principal and interest, for all cost of this suit and for all general and equitable relief. [Attorney's Name & Address etc. This was served with Requests for Admission of Facts by the Sheriff's office. I answered the Petition where I acknowledged where I lives and lacked the knowledge or information to the truth of the allegation. I also stated my defenses and answered the Admission of Facts and filed these with the court.

Thanks Shelli and I will keep you posted.

Thanks Shelli, I will keep you posted on how this goes. Did you see my post about documentation answers #7 & #8 if I need to send copies to them or not.

Oh by the way, in the original petition and any correspondence they have sent me they only reference their file number and never have referenced any account number supposedly that I had with GE Money. I don't think they even know a number.

I downloaded your document and printed it out just fine. Thanks!

Yes I don't think this JDB that is suing me is the first one this supposed debt was sold to. There may be others before them, so they will need to get a complete chain of sales from Original creditor up until they bought the supposed debt. Is that the Bill of Sale that you are referring to?

And thank you, thank you, thank you. I appreciate all your hard work and can't wait to send this back showing them that I will not fight back.

#7 & #8 requests documents to or from any party (not just GE Money) regarding the subject of this lawsuit. I did send a DV letter to this attorney's office on September 7,2010 prior to them filing suit when I first heard of this JDB saying I owed them money. I sent that letter certified mail and received a response from the attorney's office on October 5, 2010 not answering my questions and only saying the original creditor was GE Money. I then sent another DV letter on October 11, 2010 stating that they did not validate the debt by sending me a copies of documents showing that Precision owned this debt. So do I need to send them those copies since that is correspondence to "any party" regarding the subject of this lawsuit? Are they trying to catch me not telling the truth? They should have those documents since they were sent to them to validate the debt

Goodness, Thank you so much Shellie!!!!!!!! I'm going to type these up tomorrow. What do I put for the production of documents?

Thanks Spikey I thought so. Now I just need to figure out the wording when I answer those questions on the Discovery.