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browniebrownie141

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Everything posted by browniebrownie141

  1. Discovery Set 2 : 1. Deny. 2. Deny. After a reasonable inquiry, the information known or readily obtainable by defendant is insufficient to enable him to provide a response, therefore deny. ( suggested by someone thoughtful ).... OK to go ? Also: Set one will be: First Amended Defendant's response to Plaintiff's request for Admission, set ONE. Set two will be: Defendant's response to Plaintiff's request for admission, set TWO. ok to go ? Just want to make sure before I send out,...hope you all understand. Thanks
  2. Discovery set 1 question #5: Admit or Deny- Defendant has not made any payments on alleged credit account #xxxxx since June 24, 2013? The above one, should be ADMIT, right ? Just confirm.
  3. @Anon Amos: The plaintiff first sent Discovery set ONE months ago, about 29 questions among...ROA-8 questions, Interrogatories & Request for documents. I think they have 3 more in their gun. The 2 questions, came not long ago, ROA, labeled as Set TWO Discovery. FROM WHAT YOU SAID: ( #54/55) Not a problem. Also; send them the entire set of RFA's they sent you as "DEFENDANT's AMENDED RESPONSE TO PLAITIFF's RFA's SET No. 1" with DENY as the response, with no argument. That way you will clean this mess up and prevent it from getting on record. You should probably take a look at the ROG's as well and see if there is any damage control (in the form of amended ROG response) needed there as well. so...let me get this correctly....do you want me to: which one? -Defendant's Amended Response to Plaintiff's RFA's set ONE ( 8 anwsers + 2 answers from set TWO ) altogether ? OR; -Defendant's Amended Response to Plaintiff's RFA's set TWO ( only 2 answers from set TWO ) Please confirm, Million thanks
  4. And...my focus on this case should be on Legal Standing ....I guess I get this correct ?! Any comment?
  5. So, allow me ... To response their Meet & Confer letter, I would need to amend my response as: I deny. ( as simple as this?) Of course, I would need to print on pleading paper saying amended response to Discovery set 2. What do you all think?
  6. Gentlemen, I had another HSBC mastercard , I thought I mentioned it. Sorry if I did'nt make this clear.
  7. How should I write on the amended repsonse to these 2 questions: I mean, how do I include the statement ??? ...that it was a reflection of my state of mind, due to the fact that I had another HSBC account, and I don't think it was the document for the alleged account given it does not reference to any account #. Million thanks
  8. @BV80: No, that piece of HSBC mastercard acceptance DOES NOT reference to the alleged account #, nor any other account #. Also, I was not refusing to answer the question, in fact I answered, with telling my state of mind. I also indicated that I had another HSBC master card account, that 's all. I guess, the opposing attorney thought I am refusing to answer the question...!!
  9. Here are how I replied: (before they sent me the above letter) 1. "On the basis that the HSBC master card acceptance is incomplete, partial, does not reference the account number listed in the lawsuit AND defendant submitted a letter sent from HSBC Bank Neveda, NA indicating that there was another account closed by HSBC due to inactivity, thus creating a reasonable doubt as to the above mastercard acceptance is for which account, the defendant denied this is the signature of "defendant" for the alleged credit account's mastercard acceptance in the lawsuit" 2. "On the basis that HSBC mastercard acceptance copy provided by plaintiff is incomplete, partial, does not reference the account number listed in the lawsuit AND defendant submitted a letter sent from HSBC bank Neveda, indicating that there was a account closed by HSBC due to inactivity, thus creating a reasonable doubt as to the above mastercard acceptance is for which account, the defendant denied this is the genuine copy for the alleged credit account 's mastercard acceptance in the lawsuit. "
  10. HOW DO I RESPONSE IN A WAY I CAN KEEP MY STAND....AVOIDING CROSS motion MSJ from plaintiff?????
  11. URGENT URGENT URGENT ....NEED HELP HERE...... I really NEED HELP HERE, they are trying to push me....HELP: I think they are trying to use this to Cross-MSJ VS. ME .... Earlier , they sent me a 2nd Discovery with 2 questions: See Photos, Here are how I replied: 1. "On the basis that the HSBC master card acceptance is incomplete, partial, does not reference the account number listed in the lawsuit AND defendant submitted a letter sent from HSBC Bank Neveda, NA indicating that there was another account closed by HSBC due to inactivity, thus creating a reasonable doubt as to the above mastercard acceptance is for which account, the defendant denied this is the signature of "defendant" for the alleged credit account's mastercard acceptance in the lawsuit" 2. "On the basis that HSBC mastercard acceptance copy provided by plaintiff is incomplete, partial, does not reference the account number listed in the lawsuit AND defendant submitted a letter sent from HSBC bank Neveda, indicating that there was a account closed by HSBC due to inactivity, thus creating a reasonable doubt as to the above mastercard acceptance is for which account, the defendant denied this is the genuine copy for the alleged credit account 's mastercard acceptance in the lawsuit. "
  12. Gentlemen & Ladies, Don't mean to be double posting, and I apologize to Administrator if this casue a violation, just want to get attorneys to take a look and get in sight from attorney as well.... Million thanks, http://www.creditinfocenter.com/community/topic/322254-given-with-my-situation-now-how-do-i-exclude-evidence-with-some-concern/
  13. HI I am from Los Angeles, the court house for my debt collection lawsuit is Chatsworth Courthouse. Can anyone tell me, what are the requirement ( must meet ) to file a ex parte motion? Also, anyone knows the Chatsworth Courthouse policy/ rules on ex parte motion ? Anyone did that at that courthouse before ?? Thank you
  14. Hi, I am from Los Angeles, California, the court location is Chatsworth. Can anyone with California 's knowledge please tell me.. Questions about case management conference and / statement filing: JDB filed the Summon past mid June 2013. Orginal trial set was next June, but Judge moved that to November 2014. Can anyone please tell me,.... How do I find out the Case Management Conference date? ( I was told it's about 6 months after the Summon, correct? And ...I need to submit a Case Management Statement to both the Court and Plaintiff, correct ? ( is it at least 15 days from the Conf date?? Thank you.
  15. Here is the 2nd Discovery request from Plaintiff, as they have not used all 35, after these 2, they have 3 more in their chamber: Please note: the HSBC mastercard acceptance sent in as attachment with this 2nd Discovery ( see evidence above from begining of the posting.
  16. My Response to their Discovery: (I) Answer/ reply to Request for Admission: 1. I don’t remember, and I don’t recall. 2. I don’t remember, and I don’t recall. 3. I don’t remember getting periodic statements regarding the alleged credit account. 4. I don’t know as the plaintiff refused to provide the validation of debt and information I requested. 5. True, since June 24, 2013, I have not made, and did not make any payment to HSBC or Porfolio Recovery Associates, LLC, on this alleged credit account. 6. I don’t remember and I don’t recall submitting any payment towards the alleged credit account within the last 4 years prior June 24, 2013. 7. I don’t know because plaintiff, LLC has not provided, and continue to refuse to provide any documents between HSBC and them, to me. 8. Pre-legal notification(s) from Portfolio Recovery Associates,….No, I deny. The very first thing I received from Plaintiff, was the summon thru their attorney. And I challenge the plaintiff to provide any proof of mail delivery of any pre-legal notification(s) such as UPS/ Fedex/ USPS certified mail receipt/ and or signature return receipt with my signature and date & time on it. This is especially the case since they rejected my validation of debt request and cease and desist request. (II) Interrogatory I don’t remember and I don’t recall submitting a request for a credit account to HSBC Bank Nevada, N.A. I don’t remember and I don’t recall. I don’t know, I don’t remember and I don’t recall what date this alleged credit account was opened. I don’t know anyone who may have possession of any credit card for the alleged credit account. I did not authorized anyone to use the alleged credit account. I don’t remember and I don’t recall using the alleged credit account. I don’t know. And I requested a lots of information regarding this alleged account, which including but not limits to, the balance of this account, the COST that the plaintiff paid to acquire this account from HSBC, validation of debt, just to name a few, but the plaintiff and it’s attorney refuse to provide the information I requested. First, in any lawsuit, the burden of proof falls on the plaintiff, not on the defendant, it is the law that defendant is innocent until it is proven guilty. The plaintiff has yet to show any significant proof . I requested a lots of information regarding this alleged account, which including but not limits to, the COST that the plaintiff paid to acquire this account from HSBC , this is especially the case as the law stated, that plaintiff cannot suit for more than the amount (= their cost), validation of debt, just to name a few, but the plaintiff and it’s attorney refused to provide the information I requested. No, not yet. And I am gathering information and I may need to do so later. No and Yes. No, not yet to HSBC as I am gathering information and I may need to do so later. And Yes, to the Plaintiff thru it’s attorney. I would have to say No for now, I don’t remember getting periodic statements regarding the alleged credit account. I don’t remember and I don’t recall, I don’t think there was any payment made by me on this alleged credit account. I don’t remember and I don’t recall. I may need to contact HSBC Bank Nevada N.A. later. Yes, after getting the summon, that they are taking legal action against me, thru their attorney. The burden of proof falls on the plaintiff, not on the defendant, it is the law that defendant is innocent until it is proven guilty. The plaintiff has yet to show any significant proof . I requested a lots of information regarding this alleged account, which including but not limits to, the COST that the plaintiff paid to acquire this account from HSBC , this is especially the case as the law stated, that plaintiff cannot suit for more than the amount (= their cost), validation of debt, just to name a few, but the plaintiff and it’s attorney refuse to provide the information I requested. Discovery is ongoing, and Defendant intends to request proper proof of ownership of this account from Plaintiff. Considering Plaintiff did not attach same to his Complaint, Defendant suspects that he does not have such proof and is invoking the defense as stated.
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