cerulean

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About cerulean

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  1. Thank you for the documents, Seadragon.
  2. Received some responses. = = = = = = = = = = = = = = Responses from Plaintiff to Defendant's Request for Documents: I requested only two documents: the Flow Agreement, which I referenced exactly as it was worded and dated on their Bill of Sale; and the actual business record of the "List of Accounts" attached to the Flow Agreement, which I also referenced exactly as it was worded and numbered on their Bill of Sale. First they list a bunch of generic objections, but one that really caught my eye is that they say the request seeks documents that are "not in the possession, custody, or contr
  3. Will be a pleasure to site a case that actually names my plaintiff and their attorney, should the opportunity arise. Now we need the CFPB to crack down on this law suit factory like they are doing to the Hanna law firm in Atlanta.
  4. Perfect, I was trying to think of a way to tie the deficient BOP response to the Plaintiff's requests and sounds like this works. Thanks.
  5. Correct, no account statements from the Plaintiff.
  6. Hi calawyer, The plaintiff already did respond to the BOP within the ten-day period, but they only sent a Bill of Sale, redacted account listing, credit application and terms. They simply ignored the other requests in the BOP and didn't list any objections. Contemplating my next move on the BOP.
  7. Thanks RyanEX, I hadn't seen your thread before, so will read it now.
  8. Received Special Interrrogatories, Request for Admissions, and Request for Production of Documents in the mail Saturday from the Plaintiff. Special Interrrogatories: 1. State all facts upon which YOU base YOUR contention that YOU owe nothing on the ACCOUNT. 2. Describe each document that YOU believe supports YOUR contention that YOU owe nothing on the ACCOUNT. 3. State all facts upon which YOU base YOUR contention that YOU owe less than the amount prayed for in Plaintiff's Complaint on the ACCOUNT. 4. Describe each document that YOU believe supports YOUR contention that YOU owe less than t
  9. Yes, I filed the General Denial about a week before the BOP and used a form from the court that had a check box at the bottom where the Defendant can pray the Plaintiff gets nothing and Plaintiff pays for costs of court.
  10. Thanks for the various strategy suggestions. Read those threads a couple months ago, so now going to reread them, there's quite a bit of stuff to wrap my head around.
  11. Thanks for explaining that strategy, helpme. What would you do different?
  12. Thanks for the replies. In my BOP I asked for ". . . and any agreement assigning the account at issue to the Plaintiff." I had seen the Bill of Sale before during the Verification process before the case was filed. The Bill of Sale says ". . . pursuant to that certain Flow Agreement for the Purchase and Sale of Charged-Off Accounts ("Agreement") . . ." so I just called it "Agreement." Next time I request it I'll specifically ask for the "Flow Agreement" and all the terms and conditions contained therein. None yet. So, since they didn't provide a full accounting in the BOP are th
  13. I did ask for it in the Bill of Particulars, but intend to ask for it again when I send the Request for Production. How do I respond to what they did send already, and the things they didn't send?
  14. I received a reply to my Demand for Bill of Particulars (have not received anything else from plaintiff). Plaintiff sent the following: 1. Two copies of a Bill of Sale for a bundle of charged-off accounts from Wells Fargo to CACH, one copy signed by a Wells Fargo executive, and one copy signed by a CACH executive. 2. Redacted Account List for the Bill of Sale consisting of 8 pages with a single line of data on each page referring to the alleged account. 3. Signed Credit Card Account Application with a hand-written account number for the alleged account that was not on the application when o