response i received back from plaintiff. Plaintiff reserves the right to supplement and/or amend any or all responses provided herein. if Plaintiff obtains the requested documentation and/or information at a later time, plaintiff will provide them to defendant upon their receipt. 1. 'state the names and addresses of all persons having knowledge of relevant facts relating to this lawsuit." response: upon the advice of counsel, plaintiff objects to this interrogatory as it is improper as it is overly board, unduly burdensome, vague and ambiguous as to the use of the term 'knowledge or relevant facts' which the defendant fails to define. 2. " identify all documents that may relate to this action, and attach copies of each such document." response: upon the advice of counsel, plaintiff objects to this demand as it is improper as it is overly broad, unduly burdensome and requests documents protected by the attorney-client privilege and/or the work-product doctrine. subject to and without waiver of the foregoing objections, annexed hereto are copies of letter from plaintiff's counsel to defendant. a copy of the chain of title for the subject account along with the electronically transmitted information from seller. in addition, annexed hereto is a copy of the summons and complaint, copy of defendant's answer and plaintiff's interrogatories served upon defendant. plaintiff reserves the right to supplement this response prior to trial. 3"attach to your answers all documents reflecting each assignment of the account from the original creditor to the Plaintiff." response: annexed hereto is a copy of chain of title for the subject account as well as the electronically transmitted information from seller with respect t the chain of title. 4. "attach to your answers the documents which reflect all transactions and credits on the account." response: upon the advice of counsel plaintiff objects to this interrogatory as it is improper as it is overly broad, and unduly burdensome. subject to and without waiver of the foregoing objections, all transactions and credits would be listed on the monthly billing statements sent to the defendant during the active life of the account. documents responsive to this interrogatory have been requested. if and when this documentation is received it will be forward to the defendant. 5. "attach to your answers all affidavits, certifications in lieu of affidavit and declaration in lieu of affidavit which relate to this matter. response. upon the advice of counsel, plaintiff objects to this interrogatory as improper as it is vague and ambiguous as to the terms " certification in lieu of affidavit" and "declarations in lieu of affidavit". plaintiff further objects as it requires a legal interpretation and conclusion.