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  1. Thank you both so much! Regarding the answers to special interrogatories, if I don't recall or have anything, what would I say? Like the 1st question they ask is to "state all facts which base that I owe nothing on the account". Can I just use the same blanket answer I did with admissions or go with the suggestion you had under special int. that state discovery is still ongoing?
  2. I was sent a Request For admissions, request for Documents and Special Interrogations and need help answering them. I have seen a general response to admissions in this forum and may use similar, but regarding the documents, I don't have anything? The original contract was online and I printed, signed and sent back via fax. I have no record of anything else. Then, regarding the Special Interrogations, I have no idea how to answer. I would like to just settle with them but without sending this in I am going to be in trouble. My wife was battling breast cancer in 2019 and 2020 and I became her