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  1. Good afternoon all - I realize that we are in the midst of the holidays, but was really looking for some input on the production of docs I intend to serve upon a Junk Debt Buyer (Plaintiff) here in CA. I already have served a Bill of Particulars - with limited response (which I intend to motion a strike of evidence submitted). And I already have my Special Interrogatories and Request for Admissions prepared and ready to go. Just wasn't super confident about my prod. of docs. So, if you would be so kind as to review what I have and let me know what you think - it would be greatly appreciated! NOTE: BG Info - I really am wanting to focus on legal standing and lack of contract. JDB has already used improper account # (not mine) in verification letter (and failed to identify any account # in actual complaint) - though JDB sent some stmts on my acct as an improper response to the BofP... --------------- PRODUCTION OF DOCUMENTS REQUEST NO. 1:Provide any and all documentation relating to the terms and conditions of the underlying credit card contract including but not limited to; proof of the alleged credit application agreed upon by the DEFENDANT bearing the DEFENDANT’S signature, proof of each element of the alleged contract, proof of each element of a material breach, and proof of each element of damages and mitigation of damages. PRODUCTION OF DOCUMENTS REQUEST NO. 2:Provide any and all documentation, proving a complete and unbroken chain of title of the asset sale of the alleged debt owed by the Defendant from the original creditor to the initial purchaser and between the original purchaser and each subsequent assignee. PRODUCTION OF DOCUMENTS REQUEST NO. 3:Provide any and all documentation relating to the forward flow agreements (or documents of similar intent) including any and all disclaimers, warranties or representations as to the validity or accuracy of the account sold between the original creditor and the initial purchaser and between the original purchaser and each subsequent assignee. PRODUCTION OF DOCUMENTS REQUEST NO. 4:Provide any and all documentation of all charges and payments showing how the payments were allocated (interest, principal, and late fees). PRODUCTION OF DOCUMENTS REQUEST NO. 5:Provide any and all documentation proving “Account Stated” as a cause of action which include proof of prior transactions that established a debtor-creditor relationship between the PLAINTIFF and the DEFENDANT, an express or implied agreement between the PLAINTIFF and the DEFENDANT as to the alleged amount due, and an expressed or implied promise from the DEFENDANT to pay the alleged amount due. PRODUCTION OF DOCUMENTS REQUEST NO. 6:Provide any and all documentation, which support your responses to the request for admissions and interrogatories which were propounded concurrently herewith.