HumbleLearner

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About HumbleLearner

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  1. attaching some resources for others. DEFENDANT'S ORIGINAL ANSWER.docx MOTION SEEKING COURT'S PERMISSION TO CONDUCT DISCOVERY.docx
  2. Thanks @texasrocker. I'm sorry to bother, but if you have time, I have a couple questions about the request for discovery Do you have any pointers on how I should phrase my request to get JP court's approval for discovery? Should I include in my request to JP court a copy of the discovery questions I intend to send to plaintiff? I paid both these debts in full, should I include copy of bank statement showing payment in my request for discovery? I'm going to stay on top of this and get my responses in well before the 3/9 deadline.
  3. I'm new to all this and looking for resources. I purchased O'Connor's Texas Rules Civil Trials 2016 and am waiting for it to arrive. - What should my first response to Texas Justice of the Peace be? Please PM me or post links to the following: - Request for Discovery - Request for Production - Letter that I should send via certified mail to the plaintiff's attorney stating that if answers to my discovery are not received within seven days then I intend to file a motion to compel the answers This is what I have gathered for my first response to the court: - "Defendant is without information or knowledge sufficient to form an opinion as to the truth or accuracy of Plaintiff’s claim, and based on that denies generally and specifically Plaintiff’s claim." - "Plaintiff’s claim demands monies for an alleged debt for which no proof of said debt, nor proof of ownership of said debt, has been verified and exhibited." - "The plaintiff is required, by law, to trace in his statement of claim the derivation of his cause of action from his assignor so that the defendant may challenge the plaintiff’s claim that he is the present owner of the cause of action." - Per Marine Bank, 25 Pa. D. & C.3d at 267-69. A "defendant is entitled to know the dates on which individual transactions were made, the amounts therefore and the items purchased to be able to answer intelligently and determine what items he can admit and what items he can contest." Thanks in advance for any help you provide.