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mangothetango

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  1. Hi all, I am looking to mail in my request for admissions to LVNV funding (plaintiff in debt collection case). However, they have 4 attorneys under the same Law Firm working for them. The one who filed the complain is different from the attorney that served me the plaintiff's requests for discovery. In answering their discovery and sending my own requests - do I just serve them to the 1 attorney that filed the plaintiff's discovery documents to me? They all have the same address and belong to the same law group. Thank you in advance for your help!!
  2. Yes they provided 2 account statements from the original creditor In my affirmative defense I asked for proof of the ownership of the debt and the original contract which they never provided
  3. Help! I am being sued for credit card debt by a 3rd party debt collector. In my summons response, I denied the allegations on the grounds that the plaintiff hasn't proven ownership of such debt. This forum has been incredibly helpful for me when filling out the request for admissions and request for production but I am at loss on how to answer these specific interrogatories. Thank you so much, any feedback will be tremendously appreciated!! Special Interrogatory No. 1: State all facts upon which you base your contentions that you owe nothing on the account .... if you make no such contention, do not answer this. Should I just re-state my affirmative defenses ? The plaintiff never proved that I entered into contract with the original creditor nor that they own the debt. The burden of proof should lie on the plaintiff not me right? Special Interrogatory No. 2: Describe each document that you believe supports your contention that you owe nothing on the account Special Interrogatory No. 3: State all facts upon which you base your contention that you owe less than the amount prayed for in the plaintiff's complaint on the account This seems like a trick question here. How would I respond to this? In my defense I don't own this account at all, let alone owing "less" Special Interrogatory No. 4: Same as no# 2 but in relation to interrogatory No 3 Special Interrogatory No. 5: State each of your affirmative defenses how is this different form the interrogatories above? I already stated these in my summons response
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