Gristle

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Gristle last won the day on January 15 2017

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  1. Question; would you recommend I supplement my answers that I already sent back and add; objecting to the term "incident"? (Using the above recommendations) Thanks again for ALL the great feedback, if you only knew how much it meant to me, you all have been amazing!
  2. Thanks, very good stuff! I sent out my responses. However since I have (2) suits going at the same time and I just received those RFA's and ROG's I will add that info on that one. Cavalry is gonna be sorry they came after us...and by us I mean you all...thank you so very much for all the help!
  3. Question; Do I file my answer to RFA'S and ROG's with the court? I know I do proof of service but can't remeber if I need to file as well. THANKS for the HELP!!
  4. OK, here are my reponses to the Form Interrogatories please let me know what you think (all help is greatly appreciated!!) I intend to mail tomorrow; Responding Party: DEFENDANT ME REQUEST FOR SPECIAL INTERROGATORIES (SET NO.1) Requesting Party: PLANTIFF CAVALRY SPV I, as assignee of CITIBANK, N.A., ME, the defendant in the above cause, responds as follows to the first set of Special Interrogatories of Plaintiff, Cavalry SPV I, as assignee of CITIBANK, N.A.: 101.1: State the name, Address, telephone number, and relationship to you each person who prepared or assisted in the preparation of the responses to these interrogatories. ANSWER: ME, My address and phone number. 102.1: State your name, any other names by which you have been known, as your address. ANSWER: ME, my adress and phone number 102.2: State the date and place of your birth. ANSWER: OBJECTION. Defendant objects to this interrogatory on the ground that this request seeks information not relevant to the subject matter of this litigation and is not reasonably calculated to lead to discovery of admissible evidence. 102.3: State, as the time of the incident, your driver’s license number, state of issuance, the expiration date, and any restrictions. ANSWER: OBJECTION. Defendant objects to this Interrogatory on the ground that this request seeks information that is private, not relevant to the subject matter of this litigation and is not reasonable calculated to lead to discovery of admissible evidence. 102.4: State each residence address for the last five years and the dates you lived at each address. ANSWER: OBJECTION. Defendant objects to this Interrogatory on the ground that it is compound in violation of California Code of Civil Procedure section 2030.060(f). Without forgoing objection Defendant states he lives at (my address). 102.5: State the name, address, and telephone number of each employer you have had over the last five years and the dates you worked for each. ANSWER: OBJECTION. Defendant objects to this Interrogatory on the ground the information sought is improper as it goes toward post judgement remedies, which are provided for in the rules of procedure. Any attempt to contact any alleged employer of the defendant is forbidden by the Rosenthal Act and the Fair Debt Collections Act. 115.2: State in detail the facts upon which you base your contention that you are not responsible, in whole or in part, for plaintiff’s damages. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 150.1: Identify all documents that are part of the agreement and for each state the name, address, and telephone number of each person who has each document. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 150.2: State each part of the agreement not in writing, the name, address, and telephone number of each person agreeing to that provision, and the date that part of the agreement was made. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 150.3 Identify all documents that evidence ech part of the agreement not in writing, and for each state the name, address, and telephone number of the person who has each document. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 150.8: Identify each agreement excused and state why performance was excused. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 150.9: Identify each agreement terminated by mutual agreement and state why it was terminated, including dates. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 150.10: Identify each ambiguous agreement and state the facts upon which your answer is based. ANSWER: OBJECTION. Defendant objects to this Special Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. Defendant also objects on the ground that the interrogatory and complaint are vague in that they do not describe the alleged debt and any agreement giving rise to the alleged debt in sufficient detail to permit the Defendant to respond. 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, objected and has not provided 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. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars.
  5. Need some last minute help on answering Interrogatories before I post for review, here are the questions I'm stuck on; 1. State the name and address, telephone number and relationship to you of each person who prepared or assisted in the preparation of the responses to these interrogatories. Intended answer; me. 2. State your name, any other names by which you have been known and your address. Intended answer my name and address. 3. State your date and place of birth. Answer? 4.State as the time of the incident, your driver's license number, the state of issuance, the expiration date and any restrictions. Answer? I think I should object as the "incident" has yet to be proven and plaintiff has yet to fully respond to BOP. Any feed back is greatly appreciated!!
  6. OK everyone, here's what I have so far for RFA's. Please let me know your thoughts. I will be working finishing up my answers to interrogatories this week and will post once finished. As always thank you so much for your help and support!! Responding Party: DEFENDANT Me REQUEST FOR ADMISSION SET NO.1 Requesting Party: PLANTIFF CAVALRY SPV I, as assignee of CITIBANK, N.A., Me, the defendant in the above cause, responds as follows to the first set of Requests for Admission of Plaintiff, Cavalry SPV I, as assignee of CITIBANK, N.A.: 1. Admit to the genuineness of the documents attached hereto as Exhibit 1, monthly billing statements for Citibank N.A. with account number xxxxxxxxxxxx1234. NO. 1: OBJECTION. Defendant objects to this request on the ground that after a reasonable inquiry the information known or readily obtainable by him is insufficient to accurately respond to this Request. Without waving the forgoing objection Defendant responds as follows: DENIED. Discovery is still 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. 2. Admit to the genuineness of the documents attached hereto as Exhibit 2, "Card Agreement" for Citibank N.A. With account number xxxxxxxxxxxx1234. NO. 2: OBJECTION. Defendant objects to this request on the ground that after a reasonable inquiry the information known or readily obtainable by him is insufficient to accurately respond to this Request. Without waving the forgoing objection Defendant responds as follows: DENIED. Defendant reserves the right to supplement his answer to his request after Plaintiff complies in full with the Bill of Particulars. 3. You applied for and opened a credit card account with Citibank N.A. NO. 3: OBJECTION. Defendant objects to this request on the ground that it is compound in violation of section 2033.060(f). Defendant further objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided 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 supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 4. A credit card was issued to you by Citibank N.A. with the account number xxxxxxxxxxxx1234. NO. 4: Defendant objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided 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 supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 5. You used the credit card and made charges and payments to the Citibank N.A. account, with account number xxxxxxxxxxxx1234. NO. 5: OBJECTION. Defendant objects to this request on the ground that it is compound in violation of section 2033.060(f). Defendant objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided 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 supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 6. Monthly billing statements, attached hereto as Exhibit 1, were mailed to you at (my address), indicating monthly debits, credit and payments made on the account xxxxx1234. NO. 6: OBJECTION. Defendant objects to this request on the ground that it is compound in violation of section 2033.060(f). Defendant further objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided 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 supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 7. You were mailed and received a cardholder agreement for this Citibank N.A. account, with the account number xxxxxxxxxxxx1234. NO. 7: OBJECTION: Defendant objects to this request on the ground that this request is compound in violation of section 2033.60(f). Defendant further objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided 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 supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 8. The date of last payment, or transaction, occurred on December 14, 2012, on the Citibank N.A. Account, with the account number xxxxxxxxxxxx1234. NO. 8: OBJECTION. Defendant objects to this request on the ground that it is compound in violation of section 2033.060(f). Defendant further objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided the complete “account”. Without waiving the forgoing objection, defendant responds as follows: DENIED. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 9. On April 24, 2013, you were indebted to Citibank N.A. The sum of $(amount) on an accounted stated for the charges to your Citibank N.A. account with the account number xxxxxxxxxxxx1234. NO. 9: OBJECTION. Defendant objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided the complete “account”. Without waiving the forgoing objection, defendant responds as follows: DENIED. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 10. On March 31, 2016, you were indebted to Plaintiff the sum of $(less amount then on question 9) on an accounted stated for charges to the account number xxxxxxxxxxxx1234. NO. 10: OBJECTION. Defendant objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided the complete “account”. Without waiving the forgoing objection, defendant responds as follows: DENIED. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. 11. All conditions precedent to payment of the unpaid principal balance due on your Citibank N.A. account, with the account number xxxxxxxxxxxx1234 have been performed, waived, satisfied, or extinguished. NO. 11: OBJECTION. Defendant objects to this request on the gound that this request is compound in violation of section 2033.060(f). Defendant further objects on the ground that this request is vague in that the identity of the account actually 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, objected and has not provided the complete “account”. Without waiving the forgoing objection, defendant responds as follows: DENIED. Defendant reserves the right to supplement his answer to this request after Plaintiff complies in full with the Bill of Particulars. Dated this [day] of April, 2017.
  7. Great stuff!! Thank you so much!! I went to Case Management this morning, trial set for Nov. 13. The stand in attorney for Winn is a "regular" meaning she heard all 10 other cases before mine (for all kinds of different Plantiffs). She's been in the area since late 90's. She's an old pro that knew all the other attorneys and judge. She was very cordial. However, I know she is not the one putting the case together so I just need to do my part!
  8. The cover page in response to my BOP stated the following; Plantiff's complaint filed on or about November 7, 2016 is for an account stated cause of action, in addition, money lent. In Ahlin v. Crescent Commercial Corp. (1950) 100 Cal. App. 2d, the Court held that in action for an Account Stated, the Defendant is not entitled to a Bill of Particulars, since it is not necessary to prove the items of the account on which the account stated is based. (Also held in Distefano v. Hall (1963) 218 Cal. App. 2d 675, 677.) Plantiff, Cavalry SPV I, LLC, as assignee of Citibank N.A.'s response to your Demand for Bill of Particulars in the above matter is only applicable to the action for money lent. Your demand for Bill of Particulars is inapplicable as to the Account Stated cause of action, Enclosed please find Plantiff's response to Defendant's Demand for Bill of Particular, as to the Money Lent cause of action only. Should you have any questions, or need anything further, please do not hesitate to contact me directly.
  9. Given their response to my BOP and after reading 1111girls thread again; what should I send them due to their inadequate response?
  10. Here is how they responded to my BOP; Plantiff objects to each and every demand to the extent that it calls for a response evidencing or embodying confidential communications between Plantiff and their attorney on the grounds that such communications are protected by attorney client privilege. Plantiff objects to each and every demand to the extent that it calls for a response evidencing or embodying the work product of his attorney. Plantiff has not completed his investigation of the facts relating to this case, has not completed his discovery in this case and has not completed his preparation for trial. Thus, his responses and answers below are based solely upon information presently available to him. Plantiff anticipates that further discovery, independent investigation, legal research, and analysis will supply additional facts and add new meaning to existing facts, as well as establish new factual conclusions and legal contentions, all of which may lead to substantial additions or changes to and/or variations from the information set forth below. The following responses are given without prejudice to Plantiffs right to produce evidence of subsequently discovered facts. Accordingly, Plantiff reserves the right to change any and all of his responses as additional facts are ascertained, legal research is completed, and contentions are made. The responses contained herein are made in good faith effort to supply as much factual information as is presently known, but in no way should be to the prejudice of Plantiff in relation to further discovery, research or analysis. Plantiff reserves the right to amend of supplement these responses should this become necessary or appropriate. Without waiving such objections and reservations, Plantiff responds to the Defendant as follows; Plantiff is only required to produce an itemization of the account alleged within the pleadings indicating what accounts are subject of the lawsuit. Plantiff has been contacted by its attorneys of record, Winn Law Group, APC, and hereby complies with this Bill of Particulars: A diligent search and reasonably inquiry has been made in an attempt to locate the requested documents. Plantiff will comply with this request and will produce all non-privileged responsive documents in its possession, custody, or control which are relevant to the issues in this litigation. Attached hereto and incorporated herein are true and correct copies of billing statements dated August 9, 2012 to March 11, 2013.
  11. One more question; as I prepare my responses should I be sending the Plantiff anything? All I've sent so far is BOP and received their cut and paste response. I've read to lay low until I received the interrogatories. Now that they are here should I be requesting documents and push for a better response to my BOP? Thanks again for your help!!
  12. Hello everyone, still moving along. I have a Case Management hearing on Tuesday and lo and behold this past Friday I finally received the interrogatories and special interrogatories (post marked April 3 and received April 7). They all look on par with what has been posted on other threads. I will prepare my answers using the great info here and post for review this next weekend. As I understand I have 30 days (plus 5) so if I mail it by May 1 I should be good correct? Calvary sent 10 consecutive billing statements and a blanket contract agreement that looks like they printed off a website. The statements do not span the life of the account nor do they start with a zero balance so based on what I have learned here it is not too concerning. Here are the interrogatories; 1. Admit to the genuineness of the documents attached hereto as Exhibit 1, monthly billing statements for Citibank N.A. with account number xxxxxxxxxxxx1234. 2. Admit to the genuineness of the documents attached hereto as Exhibit 2, "Card Agreement" for Citibank N.A. With account number xxxxxxxxxxxx1234. 3. You applied for and opened a credit card account with Citibank N.A. 4. A credit card was issued to you by Citibank N.A. with the account number xxxxxxxxxxxx1234. 5. You used the credit card and made charges and payments to the Citibank N.A. account, with account number xxxxxxxxxxxx1234. 6. Monthly billing statements, attached hereto as Exhibit 1, were mailed to you at (my address), indicating monthly debits, credit and payments made on the account xxxxx1234. 7. You were mailed and received a cardholder agreement for this Citibank N.A. account, with the account number xxxxxxxxxxxx1234. 8. The date of last payment, or transaction, occurred on December 14, 2012, on the Citibank N.A. Account, with the account number xxxxxxxxxxxx1234. 9. On April 24, 2013, you were indebted to Citibank N.A. The sum of $(amount) on an accounted stated for the charges to your Citibank N.A. account with the account number xxxxxxxxxxxx1234. 10. On March 31, 2016, you were indebted to Plantiff the sum of $(less amount then on question 9) on an accounted stated for charges to the account number xxxxxxxxxxxx1234. 11. All conditions precedent to payment of the unpaid principal balance due on your Citibank N.A. account, with the account number xxxxxxxxxxxx1234 have been performed, waived, satisfied, or extinguished. Once again, all feedback is greatly appreciated!
  13. Happy New Year, I hope everyone had a great Holiday season! I received my response to my request for Bill of Particulars and it is quite comical, similar to what others have posted here. I will post later for all to get a good laugh. In a nut shell they sent 3 random bills and stated all the "attorney client privilege" garbage. The best part as I've mentioned before I have two cases; well they responded to both in the same envelope but the laughable part is they used the exact same cover sheet for both; same case number everything. Someone at Winn must of caught it after the attorney signed it so they put 2 post-it notes over what should have been the second claim information and then used a black sharpie to cover it up lmao! They didn't even have the decency to retype a second cover sheet! Talk about Romper Room law firm lol! I am even more confident, thanks to your help of the final outcome. More to follow, thanks again!
  14. Filed denial and POS today. Been researching my local court cases with Cavalry, looks very promising, 100's of cases in past 18months, lots of missing paper work and dismissal for improper service/lacking documentation. I'll post the exact verbage this week from the minutes, perhaps someone can interpret. Lots of default judgements and about 30%ish dismissal only couple went to trial. Also looked up the local attorney Winn sends on their behalf, passed the bar in 1990 so has experience. Saw one case dropped quick when attorney for the defendant requested a jury trial and it was granted. No worries, we got this, thanks again for all your help!!!!!