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About abelincoln

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  1. The rundown: Sued by Kohn Law Firm on behalf of Midland Funding from a discharged CC from Chase.Alleged debt is around $1500Was sent "records" only going back to around $1100Was sent "bill of sale" only showing that Midland bought (redacted amount of) accounts from Chase (for redacted sum of money)Was sent Request for admissions, interrogs, and docsReplied to above requests using info found on this siteSent my own Requests to Kohn using info found on this siteReceived the same docs from Kohn as response after about 40 days (limit in WI is 30 days, so they were late) The case was filed in Jan
  2. DEFENSES Plaintiff failed to state a claim upon which relief can be granted. Plaintiff's Complaint and each cause of action therein fail to state facts sufficient to constitute a cause of action against the Defendant for which relief can be granted. Defendant claims Lack of Standing, as the Plaintiff has not provided a chain of ownership and, therefore, has not proven legal standing to sue. Defendant claims a Failure of Consideration, as there has never been any exchange of any money or item of value between the plaintiff and the Defendant. Plaintiff did not serve a "notice of Right
  3. REQUESTS FOR DOCUMENTS REQUEST 1: Please provide copies of any payments which you feel were not appropriately applied to your account, including fronts and backs of checks. REQUEST 2: Please provide copies of any written billing disputes that you submitted regarding this account. REQUEST 3: Please provide copies of any documents that you intend on producing at trial. REQUEST 4: Produce copies of any documents in your possession regarding the account. REQUEST 5: Produce copies of any documents which you obtained and/or reviewed for purposes of investigating the validity of this debt.
  4. INTERROGATORY NO.8: Please provide the following information relevant to any billing disputes communicated by you or an authorized representative regarding the account: a. to whom the dispute was communicated and/or directed; b. list all parties involved in the communication; c. the date of the communication; d. the method of communication; e. the substance of the dispute. INTERROGATORY NO. 9: If you acknowledge having this credit card account, but your dispute is limited to the balance, please state what you believe the balance was at the time you stopped making payments. INTERROGATORY
  5. INTERROGATORY NO. 1: List your full legal name, date of birth, and the last four digits of your social security number. INTERROGATORY NO. 2: Please list all addresses at which you've resided between January 2006 and the present date, including the dates applicable to each address. INTERROGATORY NO. 3: Please list all addresses at which you've received mail between January 2006 and the present date, including the dates applicable to each address. INTERROGATORY NO. 4: If your responses to any of the Requests for Admission were anything other than unqualified admissions, set forth the factu
  6. REQUEST NO. 8: Admit that you have no records in your possession to substantiate that you made any payments on the account subsequent to XXXXXX ZZ, 2009. REQUEST NO. 9: Admit that at the time you submitted your payment of XXX.00 on or about XXXXXX ZZ, 2009, there remained an account balance of $XXXX.00. REQUEST NO. 10: Admit that you went into default on the account by failing to submit the minimum required payment. REQUEST NO. 11: Admit that you resided and/or received mail at XXXX YYYY Street, XXXXXX, WI ZZZZZ from XXXXX 2008 through UUUUU 2009. REQUEST NO. 12
  7. REQUESTS FOR ADMISSION REQUEST NO. 1: You applied for, opened, and/or were otherwise granted a credit card with the account number XXXXXXXXXXXXXXXX (hereinafter said account is referred to as the account). REQUEST NO. 2: You used the aforementioned credit card account issued to make various purchases, charges, or other transactions to acquire various goods, services, or other valuable consideration. REQUEST NO. 3: The balance due on this account is $XXXX.00. REQUEST NO. 4: The account statements attached hereto as Exhibit A are true and accurate copies of the credit card
  8. I think I may have found some important information for those dealing with JDBs in Wisconsin. I've been reading the boards for a while and recently read a Marquette Law Review on responding to admissions, interrogatories and documents. I was hoping for some feedback on my answers with this new information. First questions: what is the criteria for determining the "specificity" of the denial? Are the denials that I give in the following post considered "specific"? Many users on this board have cited lack of information or belief in refusing the admit or deny. I am assuming that in states