sadinca

Members
  • Content Count

    1,315
  • Joined

  • Last visited

  • Days Won

    69

sadinca last won the day on July 26 2018

sadinca had the most liked content!

Community Reputation

762 Excellent

About sadinca

  • Rank
    500 posts and hasn't been banned yet....

Profile Fields

  • Location
    Naranja, CA

Recent Profile Visitors

2,134 profile views
  1. sorry, i know almost nothing about arbitration. just because the did not object to arbitration doesn't mean they will actually follow through. perhaps @fisthardcheese will have more insight on this matter.
  2. Request for Production of Documents Set #1 Documents to be Produced 1. Copies of any and all correspondence between YOU (for the purposes of this Request for Production, "YOU" and "YOUR" mean and refer to [MouseRabbit] your agents, attorneys, representatives or anyone action on your behalf) and ORIGINAL CREDITOR (for purposes of this Request for Production, "ORIGINAL CREDITOR" means Citibank, N.A.) relating to the CREDIT ACCOUNT (for purposes of this Request for Production, "CREDIT ACCOUNT" means the Citibank, N.A. credit card account XXXXXXXXXXXX#### which is the subject of this lawsuit). Defendant objects to this request on the ground that the identity of the account actually at issue in this litigation remains unclear. For that reason, defendant asked plaintiff to responds to a Bill Of Particulars setting forth the contract referred to in the complaint. All the charges that were allegedly made pursuant to that contract, all credits that were made to the account, the price or charge for each item, materials or good supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff responded but did not provide the complete account. Without such information defendant is unable to provide the information sought in this request. Defendant reserves the right to supplement this answer after Plaintiff complies in full with the Bill of Particulars 2. Copies of any and all correspondences between YOU and Plaintiff relating to the CREDIT ACCOUNT. Defendant objects to this request on the ground that the identity of the account actually at issue in this litigation remains unclear. For that reason, defendant asked plaintiff to responds to a Bill Of Particulars setting forth the contract referred to in the complaint. All the charges that were allegedly made pursuant to that contract, all credits that were made to the account, the price or charge for each item, materials or good supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff responded but did not provide the complete account. Without such information defendant is unable to provide the information sought in this request. Defendant reserves the right to supplement this answer after Plaintiff complies in full with the Bill of Particulars 3. Copies of any documentation evidencing any payments make to ORIGINAL CREDITOR on said CREDIT ACCOUNT. Defendant objects to this request on the ground that the identity of the account actually at issue in this litigation remains unclear. For that reason, defendant asked plaintiff to responds to a Bill Of Particulars setting forth the contract referred to in the complaint. All the charges that were allegedly made pursuant to that contract, all credits that were made to the account, the price or charge for each item, materials or good supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff responded but did not provide the complete account. Without such information defendant is unable to provide the information sought in this request. Defendant reserves the right to supplement this answer after Plaintiff complies in full with the Bill of Particulars 4. Copies of any and all documents that support the affirmative defenses raised by YOU in this action. Defendant objects to this request on the ground that the identity of the account actually at issue in this litigation remains unclear. For that reason, defendant asked plaintiff to responds to a Bill Of Particulars setting forth the contract referred to in the complaint. All the charges that were allegedly made pursuant to that contract, all credits that were made to the account, the price or charge for each item, materials or good supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff responded but did not provide the complete account. Without such information defendant is unable to provide the information sought in this request. Defendant reserves the right to supplement this answer after Plaintiff complies in full with the Bill of Particulars 5. Copies of all correspondences from YOU regarding false or factually incorrect claims or statements that YOU believe were made to various credit reporting bureaus or services about YOUR Credit Account. Defendant objects to this request on the ground that the identity of the account actually at issue in this litigation remains unclear. For that reason, defendant asked plaintiff to responds to a Bill Of Particulars setting forth the contract referred to in the complaint. All the charges that were allegedly made pursuant to that contract, all credits that were made to the account, the price or charge for each item, materials or good supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff responded but did not provide the complete account. Without such information defendant is unable to provide the information sought in this request. Defendant reserves the right to supplement this answer after Plaintiff complies in full with the Bill of Particulars
  3. Request For Admissions 1. Admit that ORIGINAL CREDITOR issued to YOU the ACCOUNT (for purposes of the Request for Admissions, "ORIGINAL CREDITOR" means Citibank, N.A., "YOU" and "YOUR" mean and refer to [MouseRabbit] your agents, attorneys, representatives or anyone acting on your behalf, and "ACCOUNT" means the Citibank, N.A. account number XXXXXXXXXXXX#### which is the subject of this lawsuit). OBJECTION: Defendant Objects on the ground that this request is vague in that the identity of the “account” at issue in this litigation remains unclear. For that reason, Defendant has asked Plaintiff to respond to a Bill of Particulars setting forth the alleged “credit card agreement” referred to in the complaint. All the charges that were allegedly made pursuant to that “agreement”, all credits that were made to the “account”, the price or charge for each item, materials or goods supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff did not provide the complete “account.” Without such information, Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 2. Admit that YOU used said ACCOUNT (e.g., for purchases and/or cash advances). OBJECTION: Defendant Objects on the ground that this request is vague in that the identity of the “account” at issue in this litigation remains unclear. For that reason, Defendant has asked Plaintiff to respond to a Bill of Particulars setting forth the alleged “credit card agreement” referred to in the complaint. All the charges that were allegedly made pursuant to that “agreement”, all credits that were made to the “account”, the price or charge for each item, materials or goods supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff did not provide the complete “account.” Without such information, Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 3. Admit that YOU and ORIGINAL CREDITOR entered into an agreement regarding the ACCOUNT. OBJECTION: Defendant Objects on the ground that this request is vague in that the identity of the “account” at issue in this litigation remains unclear. For that reason, Defendant has asked Plaintiff to respond to a Bill of Particulars setting forth the alleged “credit card agreement” referred to in the complaint. All the charges that were allegedly made pursuant to that “agreement”, all credits that were made to the “account”, the price or charge for each item, materials or goods supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff did not provide the complete “account.” Without such information, Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 4. Admit that YOU agreed to pay ORIGINAL CREDITOR and its successors and assigned all outstanding balances owed on the ACCOUNT. OBJECTION: Defendant Objects on the ground that this request is vague in that the identity of the “account” at issue in this litigation remains unclear. For that reason, Defendant has asked Plaintiff to respond to a Bill of Particulars setting forth the alleged “credit card agreement” referred to in the complaint. All the charges that were allegedly made pursuant to that “agreement”, all credits that were made to the “account”, the price or charge for each item, materials or goods supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff did not provide the complete “account.” Without such information, Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 5. Admit that ORIGINAL CREDITOR mailed monthly statements to YOU regarding YOUR ACCOUNT. Objection: Defendant Objects on the grounds that this request is Argumentative and lacking in foundation. Specifically that any such “Monthly billing statements” were mailed. Defendant further Objects on the ground that this request is vague in that the identity of the “account” at issue in this litigation remains unclear. For that reason, Defendant has asked Plaintiff to respond to a Bill of Particulars setting forth the alleged “credit card agreement” referred to in the complaint. All the charges that were allegedly made pursuant to that “agreement”, all credits that were made to the “account”, the price or charge for each item, materials or goods supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff did not provide the complete “account.” Without waiving foregoing Objection, Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Therefore, Defendant denies. DENIED. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 6. Admit that YOU received a final statement on or around ##/##/#### from ORIGINAL CREDITOR with an outstanding balance of $####.## Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. However, Discovery is ongoing and not complete. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 7. Admit YOU never disputed, with any person or entity including the ORIGINAL CREDITOR, the statement with an outstanding balance of $####.##. Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. However, Discovery is ongoing and not complete. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 8. Admit that YOU have not paid the outstanding balance on said ACCOUNT. OBJECTION: Defendant Objects on the ground that this request is vague in that the identity of the “account” at issue in this litigation remains unclear. For that reason, Defendant has asked Plaintiff to respond to a Bill of Particulars setting forth the alleged “credit card agreement” referred to in the complaint. All the charges that were allegedly made pursuant to that “agreement”, all credits that were made to the “account”, the price or charge for each item, materials or goods supplied or other considerations rendered, and all payments or credits that have been made to the account. Plaintiff did not provide the complete “account.” Without such information, Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 9. Admit that YOU owe the Plaintiff the amounts prayed for in the Complaint. Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. However, Discovery is ongoing and not complete. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies with the Bill of Particulars. 10. Admit that YOU have no facts which would vary the amounts owed to Plaintiff. Defendant states that after a reasonable inquiry, the information known or readily available by him is insufficient to accurately respond to this Request. Based on the forgoing Defendant responds as follows: DENIED. However, Discovery is ongoing and not complete. Defendant reserves the right to amend or supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 11. Admit that YOU have no affirmative defenses against the Plaintiff's Complaint. Executed at XXXX, California on XX/XX/2019. Denied
  4. so they didn't object to any part of your request, they simply mailed those documents and about 12 statements.
  5. if the deadline falls on a sunday, you can serve them the next business day,
  6. wish we had responded the discovery questions last week before you received the response. whats the dateline for your to answer? where there any objections included in their response?
  7. So you served the BOP and received no response. Time to answer their Discovery questions
  8. do you know the format in which you are supposed to send your answers?