joe wilson

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About joe wilson

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  1. What happened to everyone??? I really could use some advise before I mail this and am running out of time????? right or wrong good or bad It will have to be mailed today.. INTERROGATORIES State the names and addresses of all persons who have knowledge of anyfacts relating to the case. Identify all documents that may relate to this action, and attach copies ofsuch document. Attach a complete copy of any written records or documents that you haveregarding defendant, along with a typed transcription of any handwritten records and documents. Identify all correspondence between plaint
  2. DOCUMENTS TO BE PRODUCED 1. ALL documents evidencing any communication between Plaintiff and Defendant in connection with the Agreement described in Plaintiff’s Petition, including letters and correspondence. 2. The alleged credit application from Account Numbers (MIDLAND Acct#) 99999999 and (XXXXX Acct#) 999999999999999 bearing the defendant’s signature; 3. The alleged credit agreement from Account Numbers (MIDLAND Acct#) 99999999 and (XXXXX Acct#) 999999999999999 that states interest rate, grace period, terms of repayment, et cetera; 4. Itemized statements or credit card statements from Ac
  3. also my admissions to the plaintiff do these look good????? ADMISSION REQUESTS 1. Plaintiff has no personal knowledge as to the mailing by the Original Creditor to Defendant of any written agreement governing the Account. ___ADMIT ___DENY 2. Plaintiff has no personal knowledge as to the mailing by the Original Creditor to Defendant of any billing statement for the Account. ___ADMIT ___DENY 3. Plaintiff has no personal knowledge as to why the Original Creditor entered any transaction, debit, credit or charge on any billing statement for the Account. ___ADMIT ___DENY 4. Neither Pla
  4. Ok I am working on my interrogatories to the plaintiff do these look good????? INTERROGATORIES State the names and addresses of all persons who have knowledge of anyfacts relating to the case. Identify all documents that may relate to this action, and attach copies ofsuch document. Attach a complete copy of any written records or documents that you haveregarding defendant, along with a typed transcription of any handwritten records and documents. Identify all correspondence between plaintiff and the defendant or itsrepresentatives, and attach copies. If you claim that the
  5. Also, I just realized the plaintiff ran my credit report on 7/7/12 is that legal????
  6. I just realized the plaintiff ran my credit report on 7/7/12 is that legal?
  7. Do you now a good place to find samples of the Interrogatories admitts and request for doc's, to send to the plaintiff???
  8. Does this mean that the plaintiff has to give access to his files???? CR 33.03 Option to produce business records Baldwin's Kentucky Revised Statutes AnnotatedRules of Civil Procedure Baldwin's Kentucky Revised Statutes Annotated Rules of Civil Procedure V Depositions and Discovery CR 33. Interrogatories to Parties Kentucky Rules of Civil Procedure (CR) Rule 33.03 CR 33.03 Option to produce business records Currentness Where the answer to an interrogatory may be derived or ascertained from the business records of the party upon whom the interrogatory h
  9. Hi Everyone, thanks for all the help. Well I got the Interrogatories admitts and request for doc's in the mail and I now need to send my own back to them, does any one know a place to get a good example of what to send????
  10. What is better? Interrogatory 6. What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account? Answer: Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence. The existence and validity of an account has not been proven. After a diligent search and reasonable inquiry defendant does not have the requested information. Interrogatory 6. What was the number of the last check you wrote to the order of the Plaintiff and/or the original c
  11. What is better? Interrogatory 3. Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, . Therefore without waiving the foregoing objection, defendant denies. Interrogatory 3. Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amoun
  12. Can i ask for this, also does any one know a good place to find a sample of interrogatories I can sen back to them? Kentucky Rules of Civil Procedure (CR) Rule 33.03 Baldwin's Kentucky Revised Statutes Annotated CurrentnessRules of Civil Procedure V Depositions and Discovery CR 33. Interrogatories to PartiesCR 33.03 Option to produce business records Where the answer to an interrogatory may be derived or ascertained from the business records of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, or from a compilation,
  13. Updated This is what I have so far, Fact No. 1 Please admit that you applied to the original creditor, GE Retail Bank/Lowe's Consumer, for the revolving credit card acount, number ##################, in question. Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies. Fact No. 2 Please admit that you made charges on the revolving credit card account. Answer: Defendant states that after a reasonable inquiry, and diligent sea
  14. No I Havent sent it yet and could use help. Because it was due on saturday I was told by someone that the mail box rule allowed me to send it on the next business day. Hope thats right.
  15. no. I am so lost on this, it seems there are to many things that can mess it up and the deadline is today, so do you think i need to change some things on this last answer