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Hi all, I really wish I had come across this site sooner than my deadline (tomorrow) to respond to the interrogatories, production, and admissions because I would have been able to sift through more responses here. Would anyone be willing to review what I have answered (many from this site, thanks!) and help with some answers that I have left out? I lost some steam and ideas to respond with around #8. I've "beat" the rent a lawyer from this office once in small claims and had a case dismissed but this one is large enough to be in Civil Court and I don't want to shoot myself in the foot so to speak. STATE OF VERMONT SUPERIOR COURT ) CIVIL DIVISION WASHINGTON UNIT ) DOCKET NO. Wncv ) Name ) Defendant, ) ) v. ) ) PORTFOLIO RECOVERY ASSOCIATES, LLC ) Plaintiff DEFENDANTS RESPONSE TO FIRST INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS, AND REQUEST FOR ADMISSIONS Defendant, (name), pro per, pursuant to V.R.C. P 33 and 34 responds to first request within thirty (30) business days of service. INTERROGATORIES Identify the person(s) who prepared and or assisted in any way defendant's answers to these interrogatories. Answer: Myself, (named) 2. State your full name, current address, and work address. Answer: Stated name, current address, OBJECTION: The information sought is improper as it goes toward post judgment remedies. 3. For each response to Plaintiff's request for Admission that is other than an unqualified admission, identify each fact to support defendant's denial or other response, identify each person who witness or otherwise has knowledge of such facts, and identify each document evidencing, constituting or otherwise relating to such facts. Answer: OBJECTION: Defendant's responses will be adequately detailed in the answer to the plaintiff's request for Admission. Defendant is not required to refute the plaintiff's claims; the plaintiff is required to prove them. 4. Identify all persons with whom defendant has communicated with relating to the subject matter of this litigation and the subject matter of any such communication. Answer: OBJECTION: relevancy to the litigation. 5. Identify any individual that the defendant is aware that has knowledge of the facts and circumstances of this case. Answer: OBJECTION: relevancy to litigation. 6. If you have lawsuits pending in which you are either a plaintiff or defendant, kindly state the following for each, name of lawyers, parties, nature of claim, date of incident, status of case where (name of court) suit is pending; any lawsuits against you personally, include all details; any payments to other creditors by defendant, details of dates and amounts, whether under other court orders and whether you have ever filed bankruptcy. Answer: OBJECTION: relevancy. Defendant is not aware of any lawsuits currently pending and has not filed bankruptcy. 7. Kindly list each and every address wherein you reside from Jan 1 2006 to the present. Answer: Defendant provides the following addresses: (listed) 8. Please list each and every person who you authorized to use with is the subject matter of this litigation, state whether you gave that person possession of your credit card Synchrony Bank Walmart credit card account ending in 0522, list that date that you revoked that persons authorization to use the credit card account. Answer: 9. If you claim that you filed a written dispute with Plaintiff, about any items appearing on your monthly billing statements, please provide the date that you sent the written dispute; the address that you sent your written dispute to; a description of you dispute; the name of the person or entity that you sent your dispute to; whether you received a response to the written dispute; and what the outcome of your dispute was. Answer: OBJECTION: the lack of any objection by a defendant does not prove the plaintiff's case of Account Stated. 10. If there are any payments which you allege you have not been credited for, please list each payment by date, amount, and payee. Answer: At this time defendant is not aware of any uncredited payments. 11. If you claim that you are not responsible for the amount claimed in the Plaintiff’s complaint, please identify the person or entity that you feel should be responsible for paying the amounts charged to your credit card account. Answer: DENIED to the extent that payments to the original creditor, the ACCOUNT, are immaterial to the extent that it has no bearing on the instant action, the purpose of which is to establish that Portfolio Recovery now owns said account and is supposedly entitled to collect, a fact which is yet unproven. 13. Please state all the facts supporting each defense that you are not responsible for the Synchrony Bank Walmart credit card account ending in 0522 balance upon which the plaintiffs claim is based. Answer: DENIED to the extent that payments to the original creditor, the ACCOUNT, are immaterial to the extent that it has no bearing on the instant action, the purpose of which is to establish that Portfolio Recovery now owns said account and is supposedly entitled to collect, a fact which is yet unproven. 14. Please identify all documents,, correspondences business entries, or other writing that you will be relying on for you defense of this claim. Answer: DENIED, as stated, above, to the extent that payments to the original creditor, the ACCOUNT, are immaterial to the extent that it has no bearing on the instant action, the purpose of which is to establish that Portfolio Recovery now owns said account and is supposedly entitled to collect, a fact which is yet unproven 15. If you will be relying upon any verbal communication for your defense of this case, please provide concise statement of the substance of each such verbal communication and state the name and address of the person making such statement. In your answer indicate what that person(s) connection is to the Plaintiff and/or to defendant. Answer: Defendant does not have a record of verbal communication at this time. 16. If you dispute any of the charges to Synchrony Bank Walmart credit card account ending in 0522, which is the subject matter of this lawsuit, please identify each charge, the amount of the charge, and explain why this is not owed to the Plaintiff for these charges. Answer: DENIED to the extent that payments to the original creditor, the ACCOUNT, are immaterial to the extent that it has no bearing on the instant action, the purpose of which is to establish that Portfolio Recovery now owns said account and is supposedly entitled to collect, a fact which is yet unproven 17. If you dispute the interest rate to Synchrony Bank Walmart credit card account ending in 0522, which is the subject matter of this lawsuit, please identify the disputed interest rate, the first date that the defendant disputed the interest rate, why the defendant believes the interest rate should be different, and what the defendant feels the correct balance due is with calculated interest. 18. If the defendant disputes the over limit charges please explain, identify and itemize all of the over the limit charges that are to be disputed for the Synchrony Bank Walmart Credit card account ending in 0522 ending in 2183. 19. If anyone investigated this matter for you, state their names, address, and state whether such investigation was reduced to writing. If said investigator obtained any signed statement or recorded statement, identify the person who gave the statement and give a brief synopsis of the statement. 20. Do you receive any exempt income? 21. Are you employed? If yes please provide the average weekly or bi weekly salary. 22. Do you own real estate? If yes please provide the form of ownership (Tenants by the Entirety, Trust etc) 23. If the defendant owns real estate in any form please provide the amount of equity that the defendant has in the real estate. 24. Please identify each individual that you intend to call as a witness in this action and please provide a brief description of the nature of their testimony. 25. Please identify any and all expert witness the defense intends to call and please provide a brief description of the nature of their anticipated testimony. REQUEST FOR PRODUCTION Identify and produce copies of documents that show use of and payments made on Synchrony Bank Walmart credit card account ending in 0522. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available. 2. Identify and produce copies of documents that provide payments made on Synchrony Bank Walmart credit card account ending in 0522. If in the form of a check please produce copies of all checks used to make payments on the Synchrony Bank Walmart credit card account ending in 0522. If in the form of a money order please produce copies of all money orders used to make payments on the Synchrony Bank Walmart credit card account ending in 0522. If payments were made electronically over the phone and authorized EFT and /or ACH payments please produce copies of Bank Statements evidencing payments made on the Synchrony Bank Walmart credit card account ending in 0522. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 3. Identify and produce any documents that relate in any way to any dispute as to charges, account balance, over the limit fees, late payment fees, and interest rates on purchase and/or cash advances pertaining to the Synchrony Bank Walmart credit card account ending in 0522. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 4. Identify and produce any documents relative to Request 3. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 5. Identify and produce all documents that are admissible to show that defendant is not liable to the Plaintiff for the amount of the damages the Plaintiff claims for Synchrony Bank Walmart credit card account ending in 0522. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 6. Identify and produce each and every document related to defendants source of exempt income if any. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 7. Identify and produce documents that relate in any way to any witnesses Defense intends to call to testify at trial. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 8. Identify and produce all documents that Defense intends to use at trial. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available 9. Identify and produce a copy of a Deed to any real property that the Defense owns. Defendant has no such documents in nirs possession at this time. Defendant reserves the right to amend nirs responses per the rules of civil procedure if such documents become available REQUEST FOR ADMISSIONS That the defendant obtained a credit card from Synchrony Bank walmart credit card account ending in 0522. NO. 1: DENIED to the extent that no application was attached hereto for evaluation. 2. That defendant has not disputed having Synchrony Bank Walmart credit card account ending in 0522. NO. 2: DENIED to the extent that no admissible evidence establishing use of the unproven account was provided for evaluation. 3. That defendant currently resides at 182 VT. NO. 3: DENIED. The address provided in the request is not the defendant's address. Defendant’s address has been correctly provided in the Interrogatory. 4. That defendant previously resided at VT. NO. 4: ADMITTED. Defendant previously resided at VT 5. That defendant received the notice from the original creditor Synchrony Bank that Synchrony Bank Walmart credit card account ending in 0522 was sold to Portfolio Recovery Associates LLC on 6/22/17. The notice is dated Jun 30 2017 NO. 5: DENIED. 6. That the defendant used and made payments on a Synchrony Bank Walmart credit card account ending in 0522. NO. 6: Admitted in part to the extent that no liability for any such payment has been established, therefore no payment is required. DENIED in part to the extent that Plaintiff has produced no admissible evidence establishing ownership or liability. 7. Each month received monthly billing statements credit card account for defendants Synchrony Bank Walmart credit card account ending 0522 at the address of VT 05602 and (address). NO. 7: OBJECTION No admissible evidence was attached hereto which would allow defendant to make an informed response. 8. The monthly billing statements show a monthly credit transaction on the Synchrony Bank Walmart credit card account ending in 0522. NO. 8: OBJECTION No admissible evidence was attached hereto which would allow defendant to make an informed response. 9. The monthly billing statements also shows the accumulated balance due on the Synchrony Bank Walmart credit card account ending in 0522. NO. 9: OBJECTION No admissible evidence was attached hereto which would allow defendant to make an informed response. 10. The monthly billing statement shows the interest charged on the Synchrony Bank Walmart credit card account ending in 0522. NO. 10: OBJECTION No admissible evidence was attached hereto which would allow defendant to make an informed response. 11. That defendant never sent a written dispute to the Plaintiff concerning any items appearing on the monthly billing statements for the account Synchrony bank walmart credit card account ending in 0522. 12. Defendant did not protest any items appearing on the monthly billing statements for the Synchrony bank walmart credit card account ending in 0522 because defendant (is accused) to be responsible for the use of the account and the amount due and owing. 13. That there are no payments made by you or anyone else on your behalf for which the Plaintiff did not credit the Synchrony Bank Walmart credit card account ending in 0522. 14. You were making payments, but at some point you stopped making your monthly payments on the Synchrony Bank Walmart credit card account ending in 0522. 15. Your last payment on your Synchrony Bank Walmart credit card account ending in 0522 was on January 12, 2016 in the amount of $158 16. You never made another payment after January 12, 2016 17. That you owe the amount claimed in the Plaintiff's complaint, $6098.78 plus costs. 18. That there are no disputed material facts requiring a trial. 19. That you admitted being the card holder of the Synchrony Bank Walmart credit card account ending in 0522 in the answer to the complaint.

Because I had a deadline looming, I had my attorney respond to a complaint filed by a JDB’s attorney. I’m going to take things over from here to keep my legal fees to a minimum. I have the Plaintiff’s first set of Interrogatories, Request for Production of Documents, and Request for Admissions. I also received a copy of the purchase agreement and bill of sale in response to “Lack of Standing” as my affirmative defense. I read an older string of messages on this site that went into detail about documents that prove the purchase or transfer of ownership from an original creditor to a JDB. Looking at what I was provided, I’m convinced the documents don’t comply with the business record exemption in the rules of evidence on hearsay. Nothing is notarized. There are no affidavits. Here’s what I received: My loan agreements were between [Acme Lending] and me. The JDB claims they purchased the loan from [ABC Lending]. In order to show transfer of ownership from [Acme Lending] to [ABC Lending], they provided a copy of an agreement titled Non-Recourse Receivables Purchase Agreement. The agreement says all receivables existing would be sold and assigned by seller to buyer. When we get into the document they claim transfers ownership from [ABC Lending] to the JDB, they only provided a short, half-page document titled Bill of Sale and Assignment. This is signed by the General Counsel of [ABC Lending]. This document assigns all of rights, title, and interest in and to “certain charged-off accounts” listed on an attached schedule. The only attachment is one line of text that includes the name of the JDB, an account number, my business name, and my name. As I mentioned, neither document/agreement is notarized. There are no affidavits. Here are my starting questions: Should I assume the JDB has additional documentation concerning ownership of the account that has not been furnished to me? Because the Plaintiff has not provided sufficient evidence that their client owns the account in question, do I have the ability to challenge their standing (in the form of a motion or other action) before I have to respond to their interrogatories and provide them with information and documents? I believe they should have to prove ownership of the account before they're entitled to any discovery.

Hello all, I'm hoping I can get some help finishing up responding to these Special Interrogatories. These are due soon and any help would be greatly appreciated! Here is some information about the case - I was sued by Patenaude & Felix for a student loan that was transferred to National Collegiate Trust. I responded with a general denial affirming that I had at one point had a loan with the Original Creditor but denied all other claims stating that I didn't have enough information to admit nor deny the allegations of the amount etc. and so I denied them. Below are the interrogatories. I need to type up the Admissions still. _______________________________________ Special Interrogatory No. 1: State the approximate date YOU (for the purposes of these interrogatories, the term “YOU” and “YOUR” refer to Defendant(s) ______, and his or her agents, including but not limited to his or her attorneys, direct or indirect employees of or connected with his or her attorneys, anyone acting on his or her behalf, or anyone subject to this or her control) opened loan number ______ as referenced in the Note Disclosure Statement attached as Exhibit “1” to this discovery request with Original Creditor ________. Response No. 1: Special Interrogatory No. 2: State each and every fact, circumstance and/or evidence which in any way supports or substantiates YOUR contention that there is no amount due, owing or unpaid by YOU to Original Creditor ____. or Plaintiff National Collegiate Student Loan Trust 2. Response No. 2: Objection. Premature as it requests information from the Defendant, prior to the completion of discovery, to state all the facts supporting its present contentions and to speculate as to its future contentions. Special Interrogatory No. 3: State in detail each and every fact, circumstance and/or evidence of any dispute(s) remaining unresolved between YOU and Original Creditor ______ or Plaintiff National Collegiate Student Loan Trust. Response No. 3: Objection. Premature as it requests information from the Defendant, prior to the completion of discovery, to state all the facts, circumstances and/or evidence of any dispute(s) remaining unresolved. Special Interrogatory No. 4: State all facts upon which you base your denial of any of the paragraphs on the Complaint in this action. Response No. 4: Special Interrogatory No. 5: State all facts upon which you base each affirmative defense to the Complaint in this action. Response No. 5: Defendant did have an agreement _________. Special Interrogatory No. 6: State the dates and amounts of any and all payments made by YOU to Original Creditor _______. or Plaintiff National Collegiate Student Loan Trust, or any other assignee, within the last four (4) years. Response No. 6: After a reasonable inquiry and diligent search, the Defendant does not have any of the requested information. The Plaintiff should already be in possession of any such information if it exists. Special Interrogatory No. 7: State each and every date within the past 4 years wherein YOU disputed the charges with Original Creditor ________ or Plaintiff National Collegiate Student Loan Trust, or any other assignee, which form the basis of Plaintiff’s Complaint. Response No. 7: Defendant does not recall whether or not there have been any disputed charges within the past 4 years. Special Interrogatory No. 8: State the name, address, and telephone number of YOUR employer. Response No. 8: Objection. Not relevant to the subject matter of this action. Special Interrogatory No. 9: For each and every denial in Plaintiff’s Request for Admissions, state the reason for such denial. Response No. 9:

(Initially, I posted this in another thread, below is what I posted there) Facts: my case is limited - under $25k, I already had my CMC, they sent me their discovery but I overlooked it and I am now past my 30 days (at about 50 days). I was just served a second time with a copy of the original discovery packet along with a cover letter that states the following: "Under section 2033.280(b), Defendant waived their right to object to any of the requests we propounded on behalf of our client. Accordingly, we now demand that they serve us with their response to request for admissions on or before ______ date WITHOUT OBJECTION." "NOTICE: "The requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010). The court shall make this order, unless it finds that the party to whom the requests for admission have been directed as served, before the hearing on the motions, a proposed response to the requests for admission that is in substantial compliance with Section 2033.220. It is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion." (C.C.P. 2033.230 (b) AND (c).) Questions: 1) Where do things stand? Can I still object/deny their interrogatories and admissions? (I can still respond by the date they are now demanding) 2) If I am able to object/deny, can I send them a BOP along with my response? It seems that some of the good objections in this thread refer to the BOP. 3) What does the "monetary sanction under chapter 7" mean exactly? Does it mean that even if I file chapter 7 bankruptcy they can still collect? It would be great to hear from you @calawyer and @shellieh98 !!!

I am not a lawyer and need assistance in responding appropriately. I only received the Interrogatories March 8th but am required to respond in 15 days after service which was arch 4th . I have some answers but I have no clue as to if they are valid. I don't want to annoy the judge. However, I want to defend myself. In some instances it's unclear what the lawyer is even asking...PLEASE HELP! I believe a breach of contract exists due to circumstances at the time the contract was initiated. I can go into further detail once I get to affirmative defenses and whether they should be included with the interrogatories or separately. Below are the questions and some of my initial answers: INTERROGATORY NO. 1: If you intend to rely upon any documents, electronically stored information, or tangible things to support a position that you have taken or intend to take in the action, including any claim for damages, provide a brief description, by category and location, of all such documents, electronically stored information, and tangible things, and identify all persons having possession, custody, or control of them (Standard General Interrogatory No. 3). If you prefer, you may attach copies of all such documents to your answers to these interrogatories in lieu of describing each such document. RESPONSE: Objection: premature: Discovery is ongoing. Defendant's preparation for trial is not complete at this time. Also, Interrogatory is compounded and contains sub parts. INTERROGATORY NO. 2: If you are relying on an oral statement or utterance for all or any part of your defense in this action, please describe in detail each such oral statement or utterance, include the identity of each person with relevant knowledge and state the dates of each oral statements and utterance. RESPONSE: INTERROGATORY NO. 3: Identify each person, other than a person intended to be called as an expert witness at trial, having discoverable information that tends to support a position that you have taken or intend to take in this action, including any claim for damages, and state the subject matter of the information possessed by each such person (Standard General Interrogatory No.1) RESPONSE: Objection. Premature. Defendant does not know who will be called as a witness for trial at this time and is still in the discovery process INTERROGATORY NO. 4: If it is your contention that you are not indebted to the Plaintiff as alleged in the Complaint or if you contend that you owe the Plaintiff only part of the amount claimed in the Complaint, state the amount you claim is due and state the factual basis for your contention. Describe, or in lieu thereof attach to your answers to these interrogatories, all documents related to or supporting any such contention. RESPONSE: INTERROGATORY NO. 5: If you contend that another person(s) or entity is responsible in whole or in part for the Plaintiffs claim or damages, then identify that person(s) or entity, and give a detailed statement of the facts upon which you rely for your contention. RESPONSE: Defendant objects to this Interrogatory on the ground that it is unduly burdensome to the extent it seeks information that is not within the current knowledge, possession, custody or control of the Defendant. INTERROGATORY NO. 6: Separately state the factual basis for each defense you have to the claims set forth in the pleadings. REASON: See AFFIRMATIVE DEFENSE SECTION INTERROGATORY NO. 7: Itemize all payments made or tendered for the debt and/or contract at issue in this case by supplying the date, amount and form of each payment made. If any payment was made by check, also state the date the check cleared or was paid by the financial institution or bank that it was drawn on. Attach copies of all checks, receipts and/or other such proof of payment to your answers to these interrogatories RESPONSE: After engaging in diligent search and reasonable inquiry, Defendant is unable to comply with this demand because the items demanded are not in plaintiff's possession, custody, or control. To the best of Defendant’s knowledge, the items demanded are more likely currently in the possession, custody, or control of Plaintiff's, therefore DENIED. INTERROGATORY NO. 8: State each and every date you communicated with the Plaintiff or the Plaintiffs agents, employees, or representatives in writing or orally, regarding matters relevant to the issues addressed in the pleadings or your defense, and for each such communication, identify the person with whom you communicated, describe the substance of the communication and identify any witnesses to the communication. If any communication was in writing, you may attach copies of all such communications to your answers to these interrogatories in lieu of describing such communications. RESPONSE: Defendants object to the Interrogatories and Requests for Production of Documents to the extent that they are overly broad, unduly burdensome, oppressive, and/or seek information that is not relevant to the issues in this lawsuit or reasonably calculated to lead to the discovery of admissible evidence. Also, Interrogatory is compounded and contains sub parts INTERROGATORY NO. 9: If you have a claim for setoff, recoupment or the like in this case, please describe in detail the factual basis for any such claim, itemize your damages related thereto and describe, or attach to your answers to these interrogatories, all documents that support your claim and your damages. RESPONSE: See AFFIRMATIVE DEFENSES Section INTERROGATORY NO. 10: If you contend that the Plaintiff did not perform all the obligations and duties it had under the contract or agreement at issue in this case, or under any statute or law, please describe the factual basis for this contention in full detail. If your contention is based on or supported by any documents, describe, or in lieu thereof attach to your answers to these interrogatories, all documents related to or supporting any such contention. RESPONSE: Defendant objects to this Interrogatory on the grounds that the interrogatory assumes there is an agreement, and that defendant is part of an agreement. Also, Interrogatory is compounded and contains sub parts INTERROGATORY NO. 11: If your residence and/or mailing addresses have changed since entering into the contract or agreement at issue in this case, please identify each such address, the time frame for each such address, and the date and method you advised the Plaintiff of each such address. RESPONSE: Defendant objects to this Interrogatory on the ground that it Seeks information that is not relevant to any issue in this action; Seeks information not calculated to lead to the discovery of admissible evidence; Seeks information not relevant to any subject matter of this action. INTERROGATORY NO. 12: Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which the expert is expected to testify, state the substance of the findings and opinions to which the expert is expected to testify and a summary of the grounds for each opinion, and, with respect to an expert whose findings and opinions were acquired in anticipation of litigation or for trial, summarize the qualifications of the expert, state the terms of the expert's compensation, and attach to your answers any available list of publications written by the expert and any written report made by the expert concerning the expert's findings and opinions (Standard General Interrogatory No. 2). RESPONSE: In response to this interrogatory requesting information about experts, no determination as to who may be called as an expert witness has yet been made (see Interrogatory 3 Response). I reserve my right to further supplement this response when such information is known to me. Also, Interrogatory is compounded and contains sub parts INTERROGATORY NO. 13: If you contend that any of the allegations set forth in the pleadings are incorrect; identify each incorrect allegation and give a concise statement of the facts upon which you rely for your contention that the allegation is incorrect. Describe, or in lieu thereof attach to your answers to these interrogatories, all documents related to or supporting any such contention. RESPONSE: See Affirmative Defense Section

Hello, this is my first post. I received a request for admissions, interrogatories, and request for production of documents. I found this previous thread and used it as my basis for responses. I tried to write everything as verbatim as possible. I am in the State of Pennsylvania. I am assuming compounded interrogatories are allowed. (Please reference Interrogatory No.3) Also, I am not sure if I need to provide three separate response pages for the admissions, interrogatories, and production of documents. I have already formatted three separate pieces of paper with the answers. Any suggestions would be greatly appreciated. Request for Production of Documents 1. Produce any and all documents evidencing proof of all payments on the subject credit card referenced in the complaint, including, but not limited to, cancelled checks, receipts, coupons, statements, accountings, memoranda, invoices, financial statements, accounting entires, diaries, charts, lists, phone records, data compliations etc. Response: Denied. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 2. Produce any and all documents you intend and/or provide testimony on as evidence at the time of trial. Response: Denied. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. Request for Admission 1. Defendant applied for the credit card referenced in the complaint. If the answer to Request for Admissions No. 1 is "denied", then supply specific written documentation supporting the denial. Response: Denied. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 2. Defendant has failed to make all required payments on the credit card. If the answer to Request for Admissions No. 2 is "denied", then supply specific written documentation supporting the denial. Response: Denied. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 3. The attached monthly statment correctly identifies the payments, charges, and balance on the account. If the answer to Reqeust for Admissions No. 3 is "denied" then supply copies of cancelled checks, both front and back, and/or if not available, specific written documenation supporting the denial. Response: Denied. Attached information is incomplete. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 4. Defendant has no submitted any written dispute as to the billing inaccuracy concering the credit card in question during the time the account was opened on September 1, 2007 until the last payment date of September 20, 2013. If the answer to the Request for Admission No. 4 is "denied", then supply copies of specific written disputes as to any billing inaccuracies. Response: Denied. Information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 5. $9,319.73 is the correct and accurate balance of the credit card account in question at the time the account was charged off. If the answer to Reqeust for Admissions No. 5 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. Response: Denied. Information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 6. Please admit that you agreed to pay Plaintiff's predecessor all amounts due resulting form the use of you credit card account, including any finance charges and other charges due under the terms of the agreement. If the answer to reqeust for admissions No. 6 is "denied" then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account Response: Denied. Information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 7. Please admit that for each month you had a balance on your credit card account, you were sent, by mail or otherwise, a bill, statment of account, invoice or other request for payment showing all transaction s billed to your account during the billing period. If the answer to Request for Admissions No. 7 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. Response: Denied. Information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. Interrogatories 1. Please identifiy the person(s) answering these Interrogatories Answer: My name 2. Please identify each and every person that has assisted you in responding to these interrogatories Answer: No one else 3. Separately, for each of your answers to Requests for Admissions 1 through 9 above where your answer is anything other than an unqualified admit, please: a. State each fact known to you upon which you rely to support your denial or qualified answer; b. If you response is that you do not have sufficient information or knowledge to admit or deny, then describe each effort you have made to acquire the information you feel would be necessary to admit or deny the request; c. Identify each document known to you which you believe contains information relevant to your answer; and d. Identify each witness known to you who may have knowledge with respect to the information upon which you rely for your denial or qualified answer and as to each witness, state the infromation you believe is known to them with respect to you answer. Answer: The Request is Unintelligible. Discovery is ongoing. Defendant's preparation for trial is not complete at this time. 4. If you filed affirmative defenses to Plaintiff's Complaint, separately for each defense please: a. State the factual basis that supports your defense; b. Identify each document known to you which you believe contains information relevant to your defense: and c. Identify each witness known to you who may have knowledge with respect to the information upon which you rely for your defense and as to each witness, please state the information you believe is known to them with respect to your defense. Answer: The Request is Unintelligible. Discovery is ongoing Defendant's preparation for trial is not complete at this time. 5. Have you ever requested Plaintiff's predecessor to open a credit card account in your name? If so, please state the credit card account number(s). Answer: No, I never requested Plaintiff’s predecessor to open a credit card account. 6. Are you aware of any credit card accounts with Plaintiff's predecessor opened in your name? If so, please state the credit card account number (s). Answer: Defendant denies allegation. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Discovery is ongoing and defendant denies the request until such time as sufficient information is known to make a different response. Interrogatory is compounded and contains subsections. 7. Have you ever made a purchase or obtained a cash advance by using a card, account number and/or account access check issued by Plaintiff's predecessor? If so, please state the credit card account number(s) and the date(s) of the purchase or cash advance. Answer: Defendant denies allegation. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. 8. Has Plaintiff's predecessor ever sent to you, by mail or otherwise, any bills, statements of account, invoices or other requests for payment? If so, identify each document and state whether you objected to it. If you have objected, identify each objection, including whether it was written or oral. Answer: Defendant denies allegation. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. 9. Have you ever objected, in writing or otherwise, to any bills, statements of accounts or invoices you were sent? Answer: Defendant denies allegation. Defendant denies the request until such time as sufficient information is known to make a different response. 10. If you keep records of purhcases or payments with respect to your credit card account with Plaintiff's predecessor, do these records show a blance owing on the account? If so, what is that balance? Answer: Defendant denies allegation. Defendant denies the request until such time as sufficient information is known to make a different response. 11. Is there any portion of Plantiff's claim that you admit you owe? If so, state the amount that you admit you owe to Plaintiff and any facts that support your claim that you do owe the rest of Plaintiff's claim. Answer: Defendant denies allegation. Defendant denies the request until such time as sufficient information is known to make a different response. 12. If you claim that the account on which Plaintiff is suing is inaccurate, specific each inaccuracy and any facts that support your conclusion that the account is inaccurate. Answer: Defendant has denied allegations, burden of proof lies on Plaintiff. Defendant's preparation for trial is not complete at this time.

In April 2015 I received a debt settlement letter from Synchrony bank to pay off my account for 1/3rd of the balance. I was in a bad spot financially so I jumped on the offer. The offer letter said I had to contact them by a certain date which I did. I spoke to a rep who gave me instructions to send a check along with a copy of the settlement letter via CMRRR which was done. Synchrony received my check but never processed it because they signed for it 2 days PAST the date to contact them on the settlement letter. They claim since they received it past the settlement date on the letter it was not accepted. My case is that I DID contact them PRIOR to the date and arrangements were made and followed through to pay the debt, Synchrony is saying that since they received my check past the date on the settlement letter to contact them they did not process the payment. Subsequently they sent me to collections and now a civil lawsuit. I have the signed green card, copy of the settlement letter sent to me and a copy of the letter I sent to them along with my check. The lawyer's office for Synchrony has sent me INTERROGATORIES to answer which I have no problem with because its all information I've provided to them previously but my question for the forum is: Can I serve the Plaintiff (lawyer's for Synchrony bank) interrogatories of my own? They are telling me "Synchrony refused your payoff because it arrived 2 days late" and I would like to know if I have the right to know who at Synchrony has the authority to say that + I would like to bring in the recorded conversations done by the attorney's office if it comes down to it in court. I think a judge would find all of this to be a waste of time but I will not pay Synchrony 4 times the amount I believed I settled for.

Hi I was recently sued by Unifund CCR, LLC for a credit card debt. I answered their summons . Now i received document for interrogatories. I was not quite sure on how to respond back to the specific questions below which ties back to the Answer that i replied back to the summons. Would greatly help if any one could help me explain what exactly they mean and template to answer. I received the same question for 12 of my affirmative Defenses. With respect to the First affirmative defense alleged by you in answer to the plaintiff’s complaint, please set forth: I. “Identify” each and every person having knowledge or claiming to have knowledge regarding this defense II. As to each such person, state his/her name, last known or present address, telephone number. III. State specifically the facts of which such person has knowledge or claims to have knowledge and how such person came to have possession of such knowledge. IV. “Identify” each and every “document” which supports, tends to support or is claimed by you to support each said defense. As to each such “document”, “identify” those facts as to which each “document” refers or relates. Attach hereto a copy of each “document”. Incase you wanted to know my Affirmative defense they are as below : 1. Defendant claims Lack of Privity as Defendant has never entered into any contractual or debtor/creditor arrangements with Plaintiff. 2. Defendant denies the allegations as there is not, nor has there ever been any agreement, written, oral or implied with Plaintiff and Defendant. 3. Plaintiff’s complaint fails to allege a valid assignment of debt and there are no averments as to the nature of the purported assignment or evidence of valuable consideration; Plaintiff’s complaint fails to allege whether or not the purported assignment was partial or complete and there is no evidence that the purported assignment was bona fide. 4. Plaintiff’s complaint further fails to allege that the assignor even has knowledge of this action or that the assignor conveyed all rights and control to Plaintiff. The record does not disclose this information and it cannot be assumed without creating an unfair prejudice against Defendant. 5. Plaintiff has not proven that they are authorized and licensed to collect claims for others in the state of New Jersey, solicit the right to collect or receive payment of a claim of another. 6. Plaintiff is barred under the Fair Debt Collection Practices Act, hereinafter called FDCPA, Section 807(2), 15 U.S.C. § 1692e(2)from collecting interest and any amount unless it is expressly authorized by the agreement creating the alleged debt or permitted by law. Plaintiff has failed to attach proper documentation to verify if such interest is allowed. 7. Defendant claims accord and satisfaction as Defendant alleges that the original creditor accepted payment from a third party for the purported debt, or a portion of the purported debt, or that the original creditor received other compensation in the form of monies or credits from the Plaintiff. 8. The Plaintiff has failed to reference with complaint proof of alleged assignment, original contract signed by Defendant, account numbers, accounting measures to come up with such sum, lack of bona fide proof this alleged debt is indeed Defendant’s. The complaint does not disclose this information and it cannot be assumed without creating an unfair prejudice against Defendant. 9. Failure to state a claim upon which relief can be granted. 10. Plaintiff’s complaint violates the statute of frauds as the purported contract or agreement falls within a class of contracts or agreements that are required to be in writing. The purported contract alleged in the complaint was not in writing and not signed by Defendant or by some another person authorized by Defendant and who was to answer to the alleged debt, default, or miscarriage of the other person. 11. Plaintiff’s complaint is time-barred by the applicable statute of limitations on credit card debt in the state of New Jersey 12. Defendant reserves the right to plead other affirmative defenses that may become applicable and/or available at a later time.

I am new here. I received a summons from AMEX Bank and the alleged debt is from AMEX credit card. I have answered the complaint and I received Requests to Admit, Interrogatories and Requests for Production. I need help in answering Plaintiff's Interrogatories.

I think I may have found some important information for those dealing with JDBs in Wisconsin. I've been reading the boards for a while and recently read a Marquette Law Review on responding to admissions, interrogatories and documents. I was hoping for some feedback on my answers with this new information. First questions: what is the criteria for determining the "specificity" of the denial? Are the denials that I give in the following post considered "specific"? Many users on this board have cited lack of information or belief in refusing the admit or deny. I am assuming that in states other than Wisconsin this is an acceptable response. In my following post, you can see that I have not used this phrase. I have, however objected to some of the requests, please see the following information Second question: Are the objections I raised in the following post sufficient? Third question: I put my defenses after all of my responses. Are my defenses formatted correctly? I would like to use the defenses that TrueQ pointed out in Midland Funding / Kohn / Wisconsin Mainly WI 425.104 & 105, WI 425.109, and WI 422.409 Fourth question: Considering that we are in Discovery now (I think), is it prudent to elect arbitration or JAMS? Fifth question: Considering that we are in Discovery now (I think), should I file a MTD? And if so, on what grounds? I hope this information is helpful to anyone dealing with JDB in Wisconsin, and any information would be most helpful!

I was hoping to get some help. I have been on this forum for 10+ years reading how you wonderful people help others. It is inspiring. Now I need some help and hope you can get me through this. I am getting sued in NJ for $4078.01 on a defaulted car loan. When this collector first tried to collect, I sent a debt validation letter in March of 2014. They responded to that more than 1 year later with an account payment history, included with a motion to sue. I answered the suit and received a card from the court that scheduled a non-jury trial for 6-22-15 at 9am. Not sure what to do next. Plaintiff sent Interrogatories, Notice to produce and request for admission at the end of April which I have not answered yet. I am thinking about requesting adjournment. Please help. 20150602115323522.pdf

Hi, I have been sued by LVNV on an alleged debt that I know nothing about. Please see my answers to the standard questions below. I filed and served my Answer/Affirmative Defenses before the deadline. The case was filed in the Travis County Justice Court, which does not allow pre-trial discovery without permission from the court. Although the court, under the rules, may grant a motion to allow discovery without hearing, this judge has set a hearing date. So far, I have not received any response from LVNV. I need form/sample interrogatories, requests for production, and requests for admission. I would love some with the instructions, definitions, etc! Is there anyone here who would be willing to post or PM me those? The more professional, the better! I have done pretty good so far at adapting what I find (instead of just blind cut and pasting), but discovery is a little more complex and I want to make sure that the judge doesn't get annoyed because I'm a pro se defendant. I've done a lot of searching here, but the links to relevant Defendant --> Plaintiff discovery all seem to be old and broken. (Versus "Here's how to answer the JDB's discovery" samples.) I want to be on the offensive. As an aside, I don't think I owe this. I've always paid my loans and credit cards on time (not judging anyone else, just saying that I think this is a bogus lawsuit so I want to "knock this one out of the park.") And in the very unlikely event that I somehow didn't pay something, and never received any statements or demands for payments or collections for 10 years (the Complaint alleges the account was opened in 2005), I haven't held/used ANY credit cards for more than 4 years before the complaint was filed. I've only used a debit card for the past 5+ years. Thanks! Answers to Standard Questions: 1. Who is the named plaintiff in the suit? LVNV 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Michael J. Scott Scott, Parnell & Associates, P.C. 3. How much are you being sued for? Approximately $3,500 4. Who is the original creditor? (if not the Plaintiff) CitiBank 5. How do you know you are being sued? (You were served, right?) Served 6. How were you served? (Mail, In person, Notice on door) In Person 7. Was the service legal as required by your state? Yes 8. What was your correspondence (if any) with the people suing you before you think you were being sued? None 9. What state and county do you live in? Travis County, TX 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) Not even sure what this account is. I haven't held a credit card (charged or paid on) in more than 4 years before the date of service and filing of the complaint. I have never left a debt unpaid as far as I know. 11. What is the SOL on the debt?: 4 years 12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Complaint Filed and Served (1 page form with very little info.) Answer and Affirmative Defenses filed and served Motion to Allow Defendant to Conduct Limited Written Discovery filed and served, hearing set 2 days from today, no opposition filed/served by LVNV yet. 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No. How do I do this? 14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. No. Didn't even know of the existence of the alleged debt before the suit was filed. 15. How long do you have to respond to the suit? I don't recall, but the Answer and Affirmative Defenses were timely filed. 16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. None. The Complaint was a 1 page form. (Edited for typo)

Here's the short version Being sued by cach, llc. Got a set of requests (tons of course!) need to answer and send them a set of my own! I need help with answers. The stuff they have is a bill of sale worse copy ever! not even legible statements with the blacked out number, of course one affidavit of someone in their company.. Here's what they want - I'm sorry there are so many pdf's but it would've take so much time to type each and every question. I'm going to go back and look at another post I saw and see if some questions I can use for advice. I also need questions to fire back at them. I appreciate ALL the help I can get. I'm ready to get rid of these people for good!

I live in Washington State - Original credit card company was Sears opened in 1983, sold to Citibank sometime around 2003. Account now at Cach, LLC, being sued through Mandarich Law Group out of California. I received original summons with NO case number - responded and objected to claims twice. Now I have received REQUEST FOR ADMISSIONS and FIRST SET OF INTERROGATORIES and REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE). I want to object to everything - but I also believe there is case law out there regarding chain of ownership on documentation. The whole suit talks about "Original debt and creditor" being Citibank, with nothing being about Sears. Here is what the RFA states: 1. Please admit you submitted an application to the original creditor for an extension of credit (for purposes of these Requests for Admissions, "original creditor" means Citibank South Dakota, N.A.) 2. Please admit the original creditor issued you the account. 3. Please admit that you and the original creditor entered into an agreement regarding the account. 4. Please admit you used the account to accrue a balance of $XX___ 5.Please admit you agreed to pay the original creditor and it's successors and assigns the outstanding balance of $XX___ on the account. 6. Please admit you never disputed, with any person or entity, including the original creditor, the outstanding balance of $XX___ on the account. 7. Please admit you have not paid the outstanding balance on the account in the sum of not less than $XX___. 8. Please admit you owe the Plaintiff the amounts prayed for in the Complaint. 9. Please admit you have no facts which would contradict the amounts owed to Plaintiff. 10. Please admit YOU have no facts to support your affirmative defenses against the Plaintiff's Complaint. 11. Please admit YOU have no documents to support your affirmative defenses against the Plaintiff's Complaint. ANY HELP?? THANKS!

Would someone be kind enough to help me in answering the following (received after I responded to the summons admitting only to my name and county residence): CACH,LLC, Plaintiff, vs Defendant( s). PLAINTIFF'S FIRST SET OF INTERROGATORIES To: me, Defendant(s). Pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, you are to answer the attached interrogatories separately, fully, in writing, and under oath. You should deliver a true copy of your answers to the undersigned attorney within thirty days after the date of service of these interrogatories. To the extent that may be required by the applicable rules of procedure and evidence you are hereby notified that Plaintiff intends to use any and all answers to the attached interrogatories as evidence at trial or any other hearing in this case. CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was furnished by mail… Law offices of --- Attorneys dedicated to debt collection DEFINITIONS A. "Issuer" refers to CITIBANK SOUTH DAKOTA, N.A .. B. "Account" or "the Account" refers to Account Number ************** with CITIBANK SOUTH DAKOTA, N.A.. C. "Card" or "the Card" refers to the [Visa, Mastercard, Discover] card that was issued on the Account. D. "Defendant," "you," "your," or "yours" refers to me E. "Plaintiff' refers to CACH, LLC and encompasses any person, employee, or other entity authorized to act on Plaintiffs behalf. F. "Identify", as used herein with regard to a person, shall mean to provide the following: (1) the person's full name; (2) any other names the person uses or has used in the past; (3) the person's residential address and telephone number; (4) the person's business addressees) and telephone number(s); (5) the person's employer and job title; (6) if the person is a former employee of Defendant, the person's last job title while so employed, and the date of termination; and (7) if the person is not an employee of Defendant but has some other connection with Defendant, for example, agent, independent contractor, officer, director, or customer, the person's connection with Defendant. G. "Identify", as used herein with regard to documents or tangible things, shall mean to describe such documents or tangible things by title, present location, usual location, custodian, and contents. H. The word "document" is used herein in its broadest sense to include any medium upon or with which information is recorded or preserved which belongs to, or is in or subject to the possession, custody or control of Defendant or Defendant's attorneys, agents, employees, trustees, representatives, professional accountants, and any attorneys with whom you may claim the right of joint defense privileges or special relationships, by whomever generated or received, including without limitation: writings; printings; drawings; graphs; charts; notes; typewriting; photographs; slides; motion pictures; videotapes or cassettes; phonograph records; tape or other mechanical recordings; ledgers; books; statements of accounts; journals; notices; letters; catalogs; canceled checks; bank statements; invoices; bills; diaries; purchase orders; memoranda of telephone communications; telegrams; telexes or "TWX's"; telecopies; drafts or preliminary versions of the foregoing; communications to or from any governmental or law enforcement subdivision, officer, or agency; and any other instrument, writing, recording, or data compilation of any nature whatsoever, including any carbon, photographic, microfilm or other type of copy of such items, whether or not such copy is different from the original by reason of any markings, additions, commentaries, revisions, deletions, or substitutions. I. "Communication" shall include, but is not limited to, any oral communications, correspondence, memoranda, reports, records and/or recordings of telephone calls and reports of meetings. J. "Person" means an individual, corporation, trust, partnership, incorporated or unincorporated association, or any other legal entity. K. "Credit bureau" means any person who, for compensation, gathers, records, and disseminates information relative to the creditworthiness, financial responsibility, paying habits, and other similar information regarding any person, for the purpose of furnishing consumer reports to third parties. L. "Chargeoff date" means April 9, 2012. M. "Possession, custody or control" when used in reference to documents or other tangible things includes, without limitation, documents or things in your personal possession, custody or control, documents or things in the possession, custody or control of your attorneys or any other agents of yours, and documents or things which you could obtain, or copies of which you could obtain by reasonable good faith effort. Possession, custody or control includes constructive possession such that the person need not have actual physical possession. As long as Defendant has a superior right to compel the production from a third party (including an agency, authority or representative), Defendant has possession, custody or control. N. "RF A" is Request for Admission. o. "RFP" is Request for Production. INTERROGATORIES AND REQUESTS Interrogatory No.1: Identify all persons who participated in the preparation of the answers to these interrogatories. Interrogatory No.2: If you contend or believe that venue of this action is not proper in the county in which this suit was filed state the factual basis of any such contention or belief. Interrogatory No. 3: If Defendant denies having received the Card identify any persons whom Defendant believes may have received the Card. Interrogatory No.4: If Defendant denies having used the Card identify any persons whom Defendant believes may have used the Card and state whether each such person was authorized by Defendant to use the Card. Interrogatory No. 5: If Defendant denies having accepted each advance on the Card, identify each advance or charge on the Card that Defendant disputes. Interrogatory No.6: If Defendant has refused to admit RFA No. 14 state the factual basis of any such refusal to admit. Interrogatory No.7: If Defendant has refused to admit RFA No. 17 state the balance that Defendant believes to have been due on the Account as of April 9, 2012 and explain how such balance was calculated. Interrogatory No.8: If Defendant has refused to admit RF A No. 18 state the date and amount of each payment that Defendant has made on the Account since April 9, 2012. Interrogatory No.9: If you have refused to admit RFA No. 22 state the facts on which you base your refusal to admit. Interrogatory No. 10: If you have refused to admit RF A No. 23 state the facts on which you base your refusal to admit. Interrogatory No. 11: If Defendant contends or believes that the debt that is the subject of this suit is the obligation of any person or entity other than Defendant, identify such other persons or entities and state the facts on which that contention or belief is based. Interrogatory No. 12: If you have refused to admit RFA No. 24 state the facts on which you base your refusal to admit. Interrogatory No. 13: Identify all persons whom you intend to call as witnesses at trial, other than rebuttal or impeaching witnesses the necessity of whose testimony cannot reasonably be anticipated before trial. InterrogatoryNo. 14: Identify all persons whom you may call as expert witnesses at trial and state the subject matter of each such person's anticipated testimony and the opinions of each such person concerning the subject matter of this litigation. Interrogatory No. 15: Identify all persons whose mental impressions or opinions have been reviewed by any person whom you may call as an expert witness at trial. Interrogatory No. 16: If you are disputing only a portion of the Account please identify which portions of the Account are disputed and which are not and state the reasons for any such disputes. Interrogatory No. 17: If you have refused to admit RFA No. 25 then, with regard to each charge comprising the Account which you contend or believe to be unreasonable, state the facts on which you base your refusal to admit. Interrogatory No. 18: Please provide the name and address of any and all banking/financial institutions with which you had an account and/or check writing privileges on September 1,2011. PLAINTIFF'S FIRST REQUESTS FOR ADMISSIONS Pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, you are requested to admit the truth of each of the matters stated below and to admit the genuineness of each of the documents that may be attached as exhibits hereto. Pursuant to Rule 1.370 the matter is admitted unless the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter within 30 days after service of the request or such shorter or longer time as the court may allow but, unless the court shortens the time, a defendant shall not be required to serve answers or objections before the expiration of 45 days after service of the process and initial pleading upon the defendant. You are to respond to each of the following requests in writing within the time provided above, by delivering or causing to be delivered to the undersigned attorney a statement admitting or denying specifically, in good faith, each matter of which an admission is requested, or stating in detail the reason{s) you cannot truthfully admit or deny the matter. DEFINITIONS A.- O. same REQUESTS FOR ADMISSIONS RFANo.l: You are a resident of the county in which this suit was filed. RFANo.2: You signed the original application for the Card in the county in which this suit was filed. RFA No.3: You used the Card to make purchases or obtain extensions of credit in the county in which this suit was filed. RFANo.4: Defendant applied to Issuer for issuance of the Card. RFA No.5: The Card was issued to Defendant. RFA No.6. Defendant received the Card. RFA No.7. Defendant accepted the Card. RFANo.8. Defendant signed the back of the Card. RFANo.9. Defendant used the Card to make purchases. RFANo.10. Defendant used the Card to obtain extensions of credit. RFANo.ll: Issuer made cash advances to Defendant, either as actual cash or in payment for purchases Defendant made from third parties by using the Card. RFANo.12: Defendant accepted each such advance on the Account. RFA No. 13: By accepting each such advance under the terms of the agreement applicable to the Account Defendant became bound to pay the amounts of such advances, plus any additional charges provided for in such agreement. RFA No. 14: Until at least the chargeoff date Issuer sent to Defendant on a monthly basis a statement of charges and balance due on the Account. RFANo.15: Defendant did not, within sixty days of the date of any billing statement on the Account send to Issuer a written dispute of the billing statement. RFA No. 16: Defendant has failed to repay all of the advances made by Issuer on the Account. RFA No. 17: The balance due, owing, and unpaid on the Account, after allowing all just and lawful payments, credits and offsets, was $4900 as of April 9, 2012. RFA No. 18: Defendant has made no payments on the Account since April 9, 2012. RFA No. 19: At least forty-five days prior to the date on which you were served with the Original Complaint in this case you received a letter from Plaintiff's attorneys requesting payment of the Account. RFANo.20: The Account was sold to Plaintiff. RFA No. 21: The Account was assigned to Plaintiff. RFANo.22: Plaintiff is presently the owner of the Account. RFANo.23: Defendant is indebted to Plaintiff for the amounts asserted in Plaintiffs Original Complaint in this case. RFANo.24: Defendant is not entitled to any setoff for sums unconnected with payments that have been made by or on behalf of Defendant. RFA No. 25: Each of the charges comprising the Account was reasonable. PLAINTIFF'S FIRST REOUESTS FOR PRODUCTION As to each Request for Production set forth below, the requested items are to be produced and delivered to the undersigned attorney at the Law Offices of, , for inspecting, copying or photographing pursuant to Rule 1.350 of the Florida Rules of Civil Procedure. These requests apply to all described documents and tangible things over which Defendant has possession, custody, or control, and production is to be made within thirty days after the date of service of these requests. All original documents produced and identified as such shall be returned to Defendant within thirty days following receipt thereof. In connection with these requests you are instructed that the phrase "possession, custody or control" has the meaning set forth in the Definitions section below. Privileged Documents: If you withhold any documents based upon a claim of privilege you are to provide a log of such documents, listing them by date, title (or description if untitled), author, and the specific privilege asserted. Lost, Discarded or Destroyed Documents: If any document requested herein has been lost, discarded, or destroyed, please identify such document by providing the following information in your response: 1. Description of document. 2. Date of disposal or loss. 3. Manner of loss. 4. Reason for disposal or explanation of loss. 5. Person authorizing disposal. 6. Persons having knowledge of disposal or loss. 7. Person disposing of document. Authentication and Use at Hearings and Trial: You are hereby notified that all documents produced in response to this request will be used in any pretrial proceeding and at trial. DEFINITIONS REQUESTS FOR PRODUCTION RFP No.1: If Defendant denies having received the Card please produce all correspondence between Issuer and Defendant. RFP No.2: If Defendant denies having received the Card please produce Defendant's checking account records for the period from the account open date through the last payment date, September 1, 2011. RFP No.3: Please produce all billing statements from Issuer to Defendant. RFP No.4: Please produce true copies all correspondence from Defendant to Issuer disputing any billing statement on the Account, together with proof of sending and receipt of such correspondence. RFP No.5: If Defendant has refused to admit RFA No. 16 produce true copies of all payments made on the Account. RFP No.6: If you have refused to admit RFA No. 18 produce true copies of all documents on which you base your refusal to admit. RFP No.7: If you have refused to admit RFA No. 23 produce true copies of all documents on which you base your refusal to admit. RFP No.8: If Defendant contends or believes that the debt that is the subject of this suit is the obligation of any person or entity other than Defendant, please produce the documents on which any such contention or belief is based. RFP No.9: If you have refused to admit RFA No. 24 produce true copies of all documents on which you base any assertion of a setoff. RFP No.lO: With regard to each expert identified in response to Interrogatory No. l3 please produce: a. the expert's resume or curriculum vitae; b. all non-privileged notes pertaining to the expert's opinions in this action; c. any reports prepared by such expert; d. all documents and materials reviewed or relied upon by such expert in preparing the report; and e. all correspondence between you or your attorneys and each such expert. RFP No. 11: With regard to each person identified in response to Interrogatory No. 14 please produce: f. the person's resume or curriculum vitae; g. all notes of such person that were reviewed by any expert identified in response to Interrogatory No. 13; h. any reports prepared by such person that were reviewed by any expert identified in response to Interrogatory No. 13; 1. all documents and materials reviewed or relied upon by such person in preparing any such report; and J. all correspondence between you or your attorneys and each such expert. RFPNo.12: Please produce all correspondence between Plaintiff (or any of its attorneys) and Defendant (or any of Defendant's attorneys). RFP No. 13: Please produce all correspondence between Issuer and Defendant. RFP No. 14: Please produce all statements of Plaintiff or any of its attorneys. RFP No. 15: Please produce all witness statements pertaining to this litigation. RFP No. 16: If you have refused to admit RF A No. 25 produce true copies of all documents on which you base any assertion of a setoff. CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was furnished by to: LAW OFFICES OF , Attorneys Dedicated to Debt collection

1. Who is suing you? The Moore Law Group 2. For how much? $21,000 3. Who is the original creditor? Capital One Bank (USA), N.A 4. How do you know you are being sued? Was Served Summons 5. How were you served? Were you served? In Person at Home 6. What was your correspondence (if any) with the people suing you before you think you were being sued? They sent a letter regarding the debt and that they were intending to collect it on Capital One Bank's behalf. They attached the last bank statement of when the account had ceased payment, along with a letter stating the same thing, which didn't show any solid proof that it was my debt. 7. Where do you live? California 8. When is the last time you paid on this account? 2013 9. What is the status of your case (if anything has been opened)? You can find this by a) calling the court or looking it up online (many states have this information posted daily). Has a case number, says summons issued, case assigned. 10. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) When they initially sent the first letter stating that they were going to collect the debt on Capital One's behalf, I replied with a letter denying the allegations, and requesting for any evidence they had. 11. Did you request debt validation before the suit was filed? If not, don't bother doing this now. Yes, and they sent a letter from the original creditor of when my account had ceased payment and a copy of the last bank statement. Other than that, they sent no other proof. There was no signature on either of the documents they sent, which seems to me that they might not even have ample evidence. 12. What evidence did they send with the summons? An affadavit? A statement from the OC? Anything else they attached as exhibits? A statement from the original creditor. 13. What is the SOL on the debt? 4 Years *I'm currently in the process of writing my discoveries and would really appreciate some guidance. I was served on October 2nd, I replied denying the allegations. They sent a letter about two weeks ago for mediation, to which I did not respond. About four days ago, they filed a Case Management Conference for me to attend in a month. I am confused as to why they are already filing a CMC so soon? I thought that happens later down the line. What should I expect from the CMC and how should I prepare for it? Should I send my discoveries before or after the CMC, if, at all? I've been reading on a couple threads that it is better to not send discoveries as it will allow them to become more prepared. So, I am conflicted as whether I should go forward with the discoveries or not, or just wait 45 days before the trial date and file a CCP 96? I'm really new to this and am not too knowledgeable about all this. Also, should I request a trial with or without jury?

Hi, I beat the MSJ and was sent these Interrogatories to answer. Need help with answering. Also, I would like to send them some of my own for discovery. Can anyone assist? STATE OF INDIANA ) IN THE MADISON CIRCUIT COURT DIVISION 5 ) SS: COUNTY OF MADISON ) CAUSE NO. MIDLAND FUNDING LLC AS SUCCESSOR ) IN INTEREST TO URBAN TRUST BANK AS ) ISSUER OF SALUTE VISA GOLD, ) Plaintiff, ) ) vs. ) XXXXXX, ) Defendant. ) PLAINTIFF’S WRITTEN INTERROGATORIES TO DEFENDANT Pursuant to Indiana Trial Rule 33, Plaintiff, Midland Funding LLC as successor in interest to Urban Trust Bank as issuer of Salute Visa Gold (“Midland”), serves upon the defendant, C and requests that C within thirty (30) days of the date indicated on the Certificate of Service, (i) respond in writing to the following Interrogatories, and (ii) provide such responses to the offices of Bowman, Heintz, Boscia & Vician, P.C., 8605 Broadway, Merrillville, IN 46410. Instructions for Answering 1. Where an interrogatory calls for an answer in more than one part, the parts should be separated in the answer so that they are clearly understandable. 2. The words “you,” “your,” “Defendant,” etc. refer to the defendant in this cause of action, C. 3. You are reminded that all answers must be made separately and fully and that an incomplete or evasive answer is a failure to answer. 4. You are under a continuing duty seasonably to supplement your responses and/or and prior responses pursuant to Indiana Trial Rule 26(E). INTERROGATORIES 1. XXX’s “Sworn Denial on Account” states, “This is not a valid debt.” Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the allegations set forth in the above excerpt from Blackwell’s “Sworn Denial on Account?” ANSWER: 2. If your answer to Interrogatory No. 1 is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, provide a detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the information. ANSWER: 3. XXX’s “Sworn Denial on Account” states, “This is not my debt.” Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the allegations set forth in the above excerpt from Blackwell’s “Sworn Denial on Account?” ANSWER: 4. If your answer to Interrogatory No. 3 is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, provide a detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the information. ANSWER: 5. XXXl’s “Sworn Denial on Account” states, “I did not sign a contract to be responsible for this debt.” Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the allegations set forth in the above excerpt from Blackwell’s “Sworn Denial on Account?” ANSWER: 6. If your answer to Interrogatory No. 5 is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, provide a detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the information. ANSWER: 7. XXXX’s “Sworn Denial on Account” states, “I did not sign a contract with this plaintiff.” Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the allegations set forth in the above excerpt from Blackwell’s “Sworn Denial on Account?” ANSWER: 8. If your answer to Interrogatory No. 7 is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, provide a detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the information. ANSWER: 9. XXXX’s “Sworn Denial on Account” states, “If I am responsible for this debt, the amount sued for is incorrect.” Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the allegations set forth in the above excerpt from Blackwell’s “Sworn Denial on Account?” ANSWER: 10. If your answer to Interrogatory No. 9 is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, provide a detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the information. ANSWER: 11. XXX “Sworn Denial on Account” states, “If I am responsible for this debt, it is barred by any applicable statute of limitations.” Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the allegations set forth in the above excerpt from Blackwell’s “Sworn Denial on Account?” ANSWER: 12. If your answer to Interrogatory No. 11 is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, provide a detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the information. ANSWER: 13. State your full name as well as any prior names you have used, your date of birth, your social security number, your marital status, and the name of your spouse. ANSWER: 14. (a) State your current residential address. ANSWER: ( State how long you have lived at your current residential address. ANSWER: © State all of your prior residential addresses from June 25, 2007 through the present. ANSWER: 15. (a) State your current mailing address. ANSWER: ( State how long you have received mailings at your current mailing address. ANSWER: © State all of your prior mailing addresses from June 25, 2007 through the present. ANSWER: 16. Have you received any bills, statements, or other correspondence from Urban Trust Bank or Salute Visa Gold concerning account number XXXXXXX? ANSWER: 17. If your answer to Interrogatory No. 14 is anything other than an unqualified “No,” please set forth the following information, specifically and in detail: (a) The approximate date the document was received. ANSWER: ( The amount of the statement and the amount, if any, that you have paid. ANSWER: © A brief description of the goods or services for which the bill or statement was submitted. ANSWER: 18. Have you received any bills, statements, or other correspondence from Midland Funding LLC concerning account number XXXXXX? ANSWER: 19. If your answer to Interrogatory No. 18 is anything other than an unqualified “No,” please set forth the following information, specifically and in detail: (a) The approximate date the document was received. ANSWER: ( The amount of the statement and the amount, if any, that you have paid. ANSWER: © A brief description of the goods or services for which the bill or statement was submitted. ANSWER: 20. Did you ever dispute any matter concerning account number XXXX with Midland Funding LLC, Urban Trust Bank, Salute Visa Gold, or any other entity since June 1, 2007? ANSWER: 21. If your answer to Interrogatory No. 20 is anything other than an unqualified “No,” then for each and every such objection, please set forth the following information specifically and in detail: (a) Was the objection in writing? If so, please identify the writing by setting forth its date, title, and a summary of the contents. (You may, instead, attach a copy of the writing.) ANSWER: ( If the objection was not written, please state the date of the objection, the name of the person to whom the objection was made, the mode of communication (i.e., by telephone, in person, etc.), and the substance of the subject conversation. ANSWER: 22. Please state the following: (a) The name of each depository financial institution or bank with which you transacted business for payment of bills from June 1, 2007 through October 31, 2008. “Depository financial institution” is defined at I.C. § 28-9-2-6, and includes, but is not limited to commercial banks and credit unions. ANSWER: ( The account number for each deposit account, financial institution account or bank account with which you transacted business for payment of bills from June 1, 2007 through October 31, 2008. “Deposit account” is defined at I.C. § 28-9-2-5, and includes, but is not limited to savings accounts and checking accounts. ANSWER: 23. Please state all of your employers, employers’ addresses, and terms of employment from June 1, 2007 through the present. ANSWER: 24. Have you asked for assistance from any persons concerning the nature of Plaintiff’s discovery requests or to prepare responses to Plaintiff’s discovery requests in this litigation? ANSWER: 25. If your answer to Interrogatory No. 24 is anything other than an unqualified “No,” please set forth the following information, specifically and in detail: The name, address, and telephone number of all responsive persons. ANSWER: 26. Describe your educational background and professional qualifications. Please include the names and addresses of all high schools, colleges, universities, post-graduate schools, and training programs that you have attended; the dates of graduation and the degrees or qualifications you receives; and any professional licenses or certifications that you hold or have held. ANSWER: 27. State the names and addresses of all persons that you propose to call as a witness to testify at the trial in this litigation. ANSWER: 28. Please provide a detailed description of all documents and/or other evidence that you propose to introduce at the trial in this litigation. ANSWER:

I have question regarding the discover, so I recently received Interrogatories, Request of Admission, and Request of documents with a package that included Affidavit of debt, affidavit of sale/transfer, credit card agreement , bank statements and etc. How would I answer Interrogatories and Request of Admission when they are providing documents that support their request? Can I still Object and Deny despite there “evidence/exhibits”? Please help in preparing answers J I have question regarding the discover, so I recently received Interrogatories, Request of Admission, and Request of documents with a package that included Affidavit of debt, affidavit of sale/transfer, credit card agreement , bank statements and etc. How would I answer Interrogatories and Request of Admission when they are providing documents that support their request? Can I still Object and Deny despite there “evidence/exhibits”? Form Interrogatories 102.1 State Your name, any other names by which you have been known, and your ADDRESS 102.4 Sate each residence ADDRESS for the last five years and the dates you lived at each ADDRESS 115.2 Sate in detail the facts upon which you base your contention that you are not responsible, in whole or in part for plaintiff’s damages Request of Admission Request No 1 GCFS is, and was at all times material to subject matter of this lawsuit, a corporation qualified to do business in California Request No 2 GCFS is, and was at all times material to the subject matter lawsuit, the owner of hlder of all rights, title, and interest in the ACCOUNT Request No 3 GCFS is the successor-in interest of the BANK Request No 4 The Agreement contains the terms and conditions that govern the ACCOUNT. Request No 5 The AGREEMENT contains a provision that YOUR use of the CREDIT CARD is acceptance of the terms and conditions of the AGREEMENT. Request No 6 BANK issued YOU the CREDIT CARD Request No 7 YOU used the Credit Card to Purchase goods and/or services, including balance transfer, cash advances, and overdraft advances, on the ACCOUNT. Request No 8 YOU E-Signed the Agreement by using the CREDIT CARD. Request No 9 On or about 2/29/2012, YOU breached the AGREEMENT Request No 10 The BANK preformed all obligations to YOU pursuant to the terms of the AREEMENT, except those obligations which they excused from preforming. Request No 11 YOU made your last payment on or about 7-7-11 Request No 12 BANK suffered damages caused by YOUR branch of the AGREEMENT in the sum of $10,561.47 Request No 13 The AGREEMENT allowed BANK to charge at least 10.00 percent interest per annum on damages caused by breach. Request No 14 YOU became indebted to BANK within the last four years. Request No 15 An account was stated in writing between the BANK and YOU. Request No 16 It was agreed that YOU were indebted to the BANK in the sum of $10,561.47 Request No 17 You have no valid affirmative defense to the causes of action in PLAINTIFF’S complaint. Request of documents All Corresponded sent by defendant regarding Wells Fargo Bank N.A Card services visa credit card account number xxxx-xxxx-xxxx-0887 All Documents correspondence, including billing statements, Defendant received regarding the above-stead credit card account. All Documents showing that Defendant is not indebted to Plaintiff in the sum of $10,xxx.xx (pulse interest) or in any sum at all Copies of any all documents support or evidence all affirmative defenses that Defendant intends to raise against plaintiffs complaint.

OK, First I would like to state my appreciation for how these forums have empowered me to take a stand against these low life criminals. I was served with a petition, and request for admission of facts. Using very helpful information on this forum, I responded to those. I made sure my responses were filed with the clerk or court as well as mailed to them certified. I also sent Eaton 2 DV letters. They responded with a stack of credit card statements from Chase as well as an affidavit from some Midland employee that I am not familliar with. The Cover letter from Eaton Grp Atty stated "We have ordered the requested documentation from our client and will forward you a copy as soon as we receive it" A few days later, 11/28/12, I received a "Request for payment arrangements" and a "Consent Judgement" for me to sign. as well as "Account Interrogatories" and "Domestic Interrogatories" The 2 forms are as follows. ACCOUNT INTERROGATORIES 1: The creditor indicates that the monthly statements itemized all purchases, payments, fees and credits and the creditor indicates a balance or $2,XXX.XX as of January 15,2012. Do your records refplect otherwise and if so, please describe. 2: The Creditor indicates that the monthly statement informed you of a right to dispute in writing within 60 days any listed purchase, payment, fee, or credit. The Creditor indicates no timely disputes. Do your records reflect otherwise and if so, please describe. 3: The creditor indicates that the monthly statement accurately reflect all purchase and fees. Do your records reflect otherwise and if so, please describe. 4: The creditor indicates that the monthly statement accurately reflect all payments and credits. Do your records reflect otherwise and if so, please describe. 5: The Creditor indicates that the credit terms are based on your agreement. You received the credit terms when the account was opened. Please fully describe and credit terms which you feel are not accurately reflected, detail the suggested accurate terms, and describe or attach any document which substantiates and agreement as to any different terms. DOMESTIC INTERROGATORIES 1: What is the present name and address of each person to whom you have been marries 2: On what date were you marries, physically separated, and petitioned for divorce relative to each person to whom you have been married. 3: Why do you feel the community should not be held responsible for this obligation? 4: What community property did you retain after your marraige ended and what was the estimates value of the property on the date of the dissolution? I have 2 questions, 1) Does anyone have suggestions on how to respond to these interrogatories? I have denied everything so far, and asked them to validate the account. 2) Do I need to file anything with the court denying the "Consent Judgement"? They sent this stuff to me regular mail, but the form appears to be one planned for filing with the court. Any help would be greatly appreciated.

Received the following interrogatories and need help answering asap. Didn't realize I only had a few days to answer. 1. If any of your responses to Plaintiff's Requests for Admissions served are not an unqualified admission, state the number of each such Request. 2. For each Request for Admission for which Your response was not an unqualified admission, state all facts upon which you base Your response. 3. For each Request for Admission for which Your response was not an unqualified admission, state the name, address and telephone number of all persons who have knowledge of those facts. 4. For each Request for Admission for which Your response was not an unqualified admission, identify all Documents and other tangible things that support your responses. 5. For each Request for Admission for which Your responses was not an unqualified admission, state the name, adddress, and telephone number of the Person who has each Document or thing that support Your responses. Thank you for any Help you can give me.

Hello all. First off; I just want to say that what you people do here is really great. Thank you. I am being sued by Midland Funding. I answered the complaint. Now they have sent me a "request for admissions" and "interrogatories". So much information out there- even on this site. Thought that since my case was unique, I would post questions and see if I could get some help. I do not remember this alleged debt, and am positive it did not occur within the last 5 years. In my response to the complaint, I denied everything (except that I was a legal entity). At the end of the answer I listed affirmative defenses as "failure to state a claim", "lack of legal capacity", and stated that "Based on the lack of information provided by plaintiff concerning alleged debt, defendant cannot properly respond with affirmative defenses at this time. If allowed by the court, the defendant reserves the right to use future affirmative defenses, if applicable; such as Statute of limitations or others that may be applicable when or if proper documentation is provided by Plaintiff". Now for Midlands Request for Admissions: (In the first paragraph they state I have 30 days to provide written responses, or the facts, the truth of which is requested, shall be deemed admitted) Request 1: Plaintiff is a banking association existing under the laws of the United States. (same as in complaint-I agreed to this in my answer by mistake) Request 2: Defendant is a resident of Gage County, Neb. Request 3: That Defendant entered into a contract under the terms of which a credit card was issued to Defendant by Plaintiff and that Defendant was extended credit by plaintiff's assignor CitiFinancial, inc. Request 4: That defendant did purchase goods and/or services on credit granted by the plaintiff's assignor, CitiFinancial, INC. Request 5: That defendant did obtain cash advances on credit granted by the plaintiff's assignor, CitiFinancial, INC. Request 6: That there is a balance of $$$$$$, past due and owing to the Plaintiff, representing both the charges and/or advances made by defendant against the credit granted by the plaintiff and other charges and fees as allowed by the contract. Request 7: That plaintiff is entitled to interest at the rate of 0% per annum, ($0 per deim). Request 8: That due demand has been made by the Plaintiff upon the Defendant more than 90 days prior to the Plaintiff's original complaint. Request 9: That the defendant is not a member of the armed forces of the United States or its Allies. Request 10: That the defendant has no affirmative defenses to Plaintiffs' complaint. Request 11: That defendant admits all allegations contained in Plaintiffs complaint. Then on a separate form was INTERROGATORIES (so do I respond "ANSWER TO INTERROGATORIES" and "ANSWER TO REQUEST" on separate documents?) INT No. 1: State your name Response: INT No 2: What is the address of your place of residence? Response: INT No 3: Please state the name and address of any and all financial institutions, banks, credit unions, or delayed deposit services utilized or patronized in the past five years by the Defendant, including, but not limited to institutions holding checking, savings, money market or certificate of deposit accounts or behalf of the defendant. Response: INT No 4: Did you make any payments to the Plaintiffs Assignor, CITIFINANCIAL? Response: INT No 5: If so, as to each payment state: -A. Date, B. amount, C. manner of payment, D. whether you have a receipt, E. will you attach a true copy of same to your answers herein without the necessity of a motion to produce? Response: INT No 6: If you deny owing the balance the plaintiff claims due from you in its complaint, please state: A: Basis of denial. B: The amount you admit owing to Plaintiff and the calculation you have used. Response: INT No 7: Did you respond to the negative to any part or portion of Plaintiff's request for admissions herein? If so, as to each negative response, set forth fully each and every fact on which you rely in support of your response based on your personal knowledge and experience the above matter and all records that you have material thereto. Response: Deadline is 30 days after service. Any help I would appreciate.

I recently received a summons to superior court in Georgia for a credit card I know nothing about. The plaintiff is Cavalry SPV and the attorney is Hanna & Assoc. I answered the summons, and now I am drafting responses to the Request for Admission of Facts, Request for Production of Documents, and Interrogatories. I am listing the questions and my answers below -- I would sincerely appreciate any advice or critiques, as this process has a very steep learning curve. Thank you in advance. Request for Admission of Facts 1. You applied for, and received, a credit card account No.XXXX from the Plaintiff. Denied. To the best of the Defendant's memory, and without any proof provided, Defendant does not remember applying for nor receiving this card. 2. You made purchases or received cash advances using the credit card, leaving a net unpaid balance on the account of $5,XXX. Denied. To the best of the Defendant's memory, and without any proof provided, Defendant does not remember using this card. 3. When you applied for the credit card, you agreed to make at least the minimum payment due every month on the indebtedness owing by you on the credit card. Defendant has already denied recollection of this card and therefore this question is improper. 4. You received the credit card agreement attached to Plaintiff's Complaint, you understood its terms and conditions and you agreed to abide by the terms and conditions imposed thereby. Denied. There was no agreement attached to Plaintiff's Complaint. 5. You made at least the minimum monthly payments owing on the credit card account for a period of time. Denied. 6. You ceased making the minimum monthly payments on the credit card. Defendant has already denied recollection of this card and therefore this question is improper. 7. You materially breached the terms and conditions of the credit card agreement, leaving you in material default on the credit card agreement. Defendant has already denied recollection of this card and therefore this question is improper. 8. You have refused to pay the principal balance due Plaintiff on the credit card. Defendant has already denied recollection of this card and therefore this question is improper. 9. You owe to Plaintiff the current past due principal balance of $5XXX. Denied. 10. You owe to Plaintiff interest on the past due balance of $4XXX. Denied. 11. You owe to Plaintiff contractual attorney's fees on the unpaid principal balance in the amount of $0. Defendant has already denied recollection of this card and furthermore has not seen a contract spelling out any legal fees claimed by Plaintiff. 12. You are legally and financially responsible to the Plaintiff for the indebtedness owing on the credit card. Denied. 13. You have benefitted, either directly or indirectly, from the use of the credit card. Denied. 14. You have not been released from liability by the Plaintiff for this debt. Defendant has already denied recollection of this card and therefore this question is improper. 15. You did not dispute any of the charges within sixty (60) days of their appearance on your monthly statement as required by your cardholder agreement. Defendant has already denied recollection of this card and therefore this question is improper. 16. There is no legal or factual basis to support any defense, claim or contention asserted by you in your Answer. Denied. 17. You do not have any documents that support your contention that the amount claimed due in the Complaint is incorrect. Admit. Defendant has never had an account with the Plaintiff or any of the three entities referenced in the Complaint as an alleged "original creditor" and therefore has no documentation regarding any account for any purpose as defined in the complaint. 18. You do not have any legal or factual basis for your contention that a different amount is owed than that claimed by the Plaintiff. Denied. See 17. 19. You do not have any legal or factual basis for your defense of failure to state a claim upon which relief can be granted. Denied. 20. You do not have any legal factual basis for your defense of lack of standing. Denied. Defendant has never had an account with the Plaintiff or any of the three entities referenced in the complaint as an alleged "original creditor" therefore Plaintiff lacks standing to sue Defendant for recovery of non-existent debt. 21. You do not have any factual basis for your claim that Plaintiff does not have a valid assignment. Denied. Plaintiff has attached no documents which demonstrate legal assignment of any debt that Defendant is personally responsible for to Plaintiff. 22. You do not have any legal or factual basis for your defense that within Complaint is not being prosecuted by the real party in interest. Denied. Defendant has never entered into any contractual agreement with Plaintiff for any reason and does not owe Plaintiff any money. 23. You have no defense to this lawsuit. Denied. Defendant preserves their right to use any defense allowed by the laws of the state of Georgia in trial and appeal. Any comments are welcome. I will post the Interrogatories next.

I've spent hours on this site formulating my response to the first set of interrogatories, request for admissions and request for production of documents. Would you mind reviewing my answers to confirm they are legally sound? I did have this account and owe money, but due to loss of employment I can neither pay my debt nor hire an attorney. I truly appreciate your assistance! STATE OF INDIANA IN THE XXXXXX SUPERIOR COURT II COUNTY OF XXXXXX CAUSE NO. XXXXXXXXXXXXXXXXXXX ASSET ACCEPTANCE, LLC PLAINTIFF VS. KELLY XXXXXXX DEFENDANT DEFENDANT’S RESPONSE TO FIRST SET OF INTERROGATORIES, REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION OF DOCUMENTS NOW COMES the Defendant, KELLY XXXXXX, responds to Plaintiff’s, ASSET ACCEPTANCE, LLC, First Set of Requests for Admission, Interrogatories and Requests for Production of Documents as follows: INTERROGATORIES Interrogatory No. 1 Please state your full name, address, date of birth, place of birth, and social security number. a. Kelly XXXXXXXXXXXXX. Regarding date of birth, place of birth and social security number, responding party objects on the grounds that this information is personal in nature, and has no bearing on the issue that is the subject of this litigation, nor will it lead to the discovery of admissible evidence. Interrogatory No. 2 What is the name and address of the bank where you have your checking account? a. Objection. Irrelevant, will not lead to any legal conclusion. Interrogatory No. 3 What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account? a. Objection. The Defendant has already denied the alleged debt in the original complaint. If the Defendant has denied the allegations why would the Defendant have this information in her custody? Burden of proof rests with the Plaintiff. The Plaintiff is on a fishing expedition, the Plaintiff has filed suit, therefore this information should be known to the Plaintiff. Interrogatory No. 4 Identify any payment that you have made to the original creditor, Dell Financial Services/CIT Online Bank, and state the date of the last payment you made to the original creditor and the amount of that payment. b. Objection. The Defendant has already denied the alleged debt in the original complaint. If the Defendant has denied the allegations why would the Defendant have this information in her custody? Burden of proof rests with the Plaintiff. The Plaintiff is on a fishing expedition, the Plaintiff has filed suit, therefore this information should be known to the Plaintiff. Interrogatory No. 5 Identify any payment that you have made on the Account, number 6879450 1290644564 14, and state the date of the last payment you made on the Account and the amount of that payment. a. The Defendant has already denied the alleged debt in the original complaint. If the Defendant has denied the allegations why would the Defendant have this information in her custody? Burden of proof rests with the Plaintiff. The Plaintiff is on a fishing expedition, the Plaintiff has filed suit, therefore this information should be known to the Plaintiff. Interrogatory No. 6 What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account? a. The Defendant has already denied the alleged debt in the original complaint. If the Defendant has denied the allegations why would the Defendant have this information in her custody? Burden of proof rests with the Plaintiff. The Plaintiff is on a fishing expedition, the Plaintiff has filed suit, therefore this information should be known to the Plaintiff. Interrogatory No. 7 Please list the date and amount of all payments made by check, money order, banks official check or any other means, that you claim were made on the Account. a. The Defendant has already denied the alleged debt in the original complaint. If the Defendant has denied the allegations why would the Defendant have this information in her custody? Burden of proof rests with the Plaintiff. The Plaintiff is on a fishing expedition, the Plaintiff has filed suit, therefore this information should be known to the Plaintiff. Interrogatory No. 8 Is the amount that you owe on the Account sued upon correct and, if not, what is the correct ", amount? a. The Defendant has denied the existence of any alleged account in the complaint. If information exists that proves there is an account balance the burden of proof rests with the Plaintiff. Interrogatory No. 9 If any offers of settlement were made to you on your Account, please state the name, address, and phone number of the person and company who offered you the settlement and how long the settlement was good for? a. Information of this sort, if it exists, should already be known to the Plaintiff. The Defendant has no legal duty to help the Plaintiff prove their case. Plaintiff is on a fishing expedition. Interrogatory No. 10 Please state the manner in which you paid any settlement that you allege was made (i.e, check, money order, etc.). a. The Defendant has denied the existence of any alleged account in the complaint. Information of this sort, if it exists, should already be known to the Plaintiff. The Defendant has no legal duty to help the Plaintiff prove their case. Plaintiff is on a fishing expedition. Interrogatory No. 11 Have you ever received a settlement letter or paid in full receipt evidencing an amount you paid toward the Account sued upon? a. Information of this sort, if it exists, should already be known to the Plaintiff. The Defendant has no legal duty to help the Plaintiff prove their case. Plaintiff is on a fishing expedition. Interrogatory No. 12 Please provide the following information for each person you will call as a witness at the trial of the captioned matter: 1. Name, address, and telephone number; 2. Place of employment; 3. Relation to the Defendant; 4. The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness. a. Objection. Premature. Defendant does not know who will be called as a witness for trial at this time and is still in the discovery process. Also, interrogatory calls for legal conclusion as Defendant is asked to provide information not known to her on an alleged account that is disputed. Interrogatory No. 13 Please identify and describe each exhibit you will use in the trial of the captioned matter. a. Objection. Premature, discovery is still ongoing, defendant has not completed trial preparation. Interrogatory No. 14 Are you currently involved in any litigation in which you are a Plaintiff! If so, then: 1. In what court is this matter pending? 2. What is the nature of this claim? a. Objection. Irrelevant, will not lead to any legal conclusion. Interrogatory No. 15 State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action. a. Objection. Premature. Discovery is ongoing. Defendant has denied allegations, burden of proof lies on Plaintiff. Also calls for testimony. Defendant's preparation for trial is not complete at this time. Interrogatory No. 16 As to each defense set out in response to Interrogatory Thirteen (13), above, state the following as to notification to Plaintiff by Defendant of such defenses: (a) the date or dates when notification was given; ( the manner in which notification was given; and © the specific party or parties to whom notification was given. a. See response to Interrogatory Thirteen (13), REQUESTS TO ADMIT FACTS The Plaintiff requests that the Defendant answer the following requests to admit facts pursuant to, and in accordance with, Indiana Rule of Trial Procedure 36. If the Defendant objects to any requested admission, the reasons therefore shall be stated. The Defendant's answer shall specifically admit or deny the requested admission, or set forth in detail the reasons why the Defendant cannot truthfully admit or deny the requested admission. A denial shall fairly meet the substance of the requested admission, and when good faith requires that the Defendant qualify an answer or deny only a part of the matter of which an admission is requested, the Defendant shall specify so much of it as is true and qualify or deny the remainder, again detailing the specificity of the denial or the part thereof. Fact No. 1 Please admit that you applied to the original creditor, Dell Financial Services/CIT Online Bank, for the account, number XXXXXXXXX, in question. a. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. Fact No. 2 Please admit that you are indebted to the Plaintiff in the amount of $1XX, plus any accrued interest, as shown on Plaintiffs Complaint. a. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. Fact No. 3 Please admit that you made payment(s) on your account. a. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. Fact No. 4 Please admit that you owe the balance on the Account to the Plaintiff. a. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. Fact No. 5 Please admit that the correct balance is outlined in the Complaint. a. The information known or obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response. Fact No. 6 Written demand for payment of the charges subject of this action was made upon Defendant by Plaintiff or Plaintiffs counsel thirty (30) days or more prior to the filing of the Complaint in this action. a. Denied. Written demand for payment never received by Defendant. DOCUMENTS TO BE PRODUCED 1. Please provide copies of any and all payments made on the account sued upon, for example, all canceled checks, money order receipts, etc., including a copy of any payment which you allege paid off or settled the account sued upon. a. Defendant has none at this time but if any become known to the Defendant during these proceedings the Defendant reserves the right to present those documents at such time. 2. Please provide copies of any and all settlement letters or offers to settle regarding the Contract sued upon. a. Defendant has none at this time but if any become known to the Defendant during these proceedings the Defendant reserves the right to present those documents at such time. 3. Please provide copies of any and all receipts, letters, or other information that supports your contention that the account was paid in full. a. The Defendant has denied the existence of any alleged account in the complaint. Information of this sort, if it exists, should already be known to the Plaintiff. The Defendant has no legal duty to help the Plaintiff prove their case. Plaintiff is on a fishing expedition. 4. Please provide copies of any and all exhibits and/or evidence that you intend to introduce at trial. a. Objection. Premature, discovery is still ongoing, defendant has not completed trial preparation. 5. If you are currently involved in any litigation as a Plaintiff, inside or outside of the state of Kentucky, please provide a copy of the petition for damages, including amendments and responses. a. Defendant has none. 6. Please provide copies of all notice letters, collection letters, statements and charge slips in your possession on the contract sued upon. a. Defendant has none at this time but if any become known to the Defendant during these proceedings the Defendant reserves the right to present those documents at such time.

Cavalry SPV I, LLC is suing me. A Civil Suit was filed against me (and my wife on a similar but unrelated case) in Hamilton County, Indiana on November 13, 2013 for which I submitted Answers and Affirmative Defenses on December 3, 2013. I received a Request for Interrogatories and Admissions about two weeks ago. My mail was forwarded to my current address as I have been out-of-state caring for a sick father. The Certificate of Service is dated December 27, 2013. Included was a cover letter and disc (pursuant to Indiana Trial Rule 26(A)). Please find the information filed with the court, a list of submitted documents, and my first attempt at answering Interrogatories #1-6. I will post Admissions #1-10 under a separate topic. I am fairly sure that I answered Interrogatories #1-4 correctly. I am uncertain about #5&6. I could really use reassurance and assistance. Thank You in Advance, Hoosier46060 PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT Comes now plaintiff, Cavalry SPV I, LLC As Assignee of, Bank of America/FIA Card Services, N.A., by counsel, pursuant to Rule 33 of the Indiana Rule of Trial Procedure, and propounds the following interrogatories to the defendant, Hoosier46060, and requests the same be answered separately and in writing, under oath, within thirty (30) days from the date of service hereof and that a copy of the same be served on the attorneys for the plaintiff, Indiana Law Firm, 123 Address Road, Suite 456, City, Indiana, 46xxx. INTERROGATORY NO. 1: Provide your full name, last four (4) digits of your social security number and date of birth. ANSWER: The Defendant’s full name is Hoosier46060. Objection to the balance of the interrogatory on the grounds that it is personal, confidential and private. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence. INTERROGATORY NO. 2: Did you have a revolving charge account (credit card) with Bank of America/FIA Card Services, N.A.? ANSWER: Defendant cannot identify the information requested as the request is too broad and the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 3: Did the revolving charge account (credit card) with Bank of America/FIA Card Services, N.A. have a number of xxxxxxxxxxxx9554? ANSWER: Defendant cannot identify the information requested as the request is too broad and the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 4: Did you use the revolving charge account (credit card) with Bank of America/FIA Card Services, N.A. to purchase goods or services, or obtain cash advances? ANSWER: Defendant cannot identify the information requested as the request is too broad and the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 5: Did you ever dispute, in writing, owing any amounts to Bank of America/FIA Card Services, N.A., as it pertained to charges on the revolving charge (credit card) referred to above? If your answer to this Interrogatory is “yes”, attach a copy of every written dispute to your answers to these Interrogatories. ANSWER: Defendant cannot identify the information requested as the request is too broad and the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 6: State the date and amount of every payment you have made since the date of charge-off, said date being 11/03/2010. RESPONSE: Defendant cannot identify the information requested as the request is too broad and the information requested is not within the answerer’s personal knowledge or records. Respectfully submitted, INDIANA LAW FIRM 123 Address Road, Suite 456 City, Indiana, 46xxx (123) 456-7890 Attorney for Plaintiff Certificate of Service The undersigned certifies that service of the foregoing pleading or document has been made by: _ Delivering it, via hand delivery or courthouse mail X Depositing it in the United States mail, postage prepaid on the 27 day of December, 2013, to the following named persons: Hoosier46060, 123 Address Ct., City, IN 46xxx Signed by Attorney for Plaintiff Attached Document List: Bank of America Statement dated July 9 – August 6, 2010 (3 pages) Bank of America Statement dated October 7 – November 5, 2010 (3 pages) Credit Card Agreement (44 pages)

So I was (am) being sued by Midland Funding and I've already gone through all the preliminary steps. My trial was set for last Dec., 2012. I showed up to the trial very well prepared and when the judge called my name he said the case was stricken (which I think means just taken off the calendar). So I went home and haven't heard from Midland's lawyers in over a year. Fast forward to Dec. 2013 and I unexpectedly get RFAs, Interrogatories and Req. for Prod. of Documents in the mail regarding this case. I'm not too worried because I'm thinking it's a last ditch effort to get me to admit something, but just in case I would like to run some of my answers by some of the more experienced folks here to make sure I don't screw something up. I appreciate the help! Here is my first attempt at answering the Interrogatories (I'm not feeling too confident about my answers to No. 11 and No. 17): INTERROGATORY NO. 1: State the name of any and all banks or credit unions where Defendant banked, included but not limited to all banks, credit unions or other financial institutions where defendant had a saving s account, checking account, received a mortgage, received a car loan, received a credit cards from, received a line of credit from, received a home equity loan, received any other type of loan, received a money order from, received a cashier's check from, or had any other financial relationship with for the last six yers. RESPONSE: Objection on the grounds that it is personal, confidential and private. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence. INTERROGATORY NO. 2: State the name of all those participating and responding to these Interrogatories. RESPONSE: My name INTERROGATORY NO. 3: State the Defendant's social security number RESPONSE: Objection on the grounds that it is personal, confidential and private. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence. INTERROGATORY NO. 4: State the Date of Birth of Defendant RESPONSE: Objection on the grounds that it is personal, confidential and private. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence. INTERROGATORY NO. 5: State all addresses Defendant has resided at or received mail at during the previous 6 years. RESPONSE: Objection on the grounds that it is personal, confidential and private. It is also overly broad and unduly burdensome. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence. INTERROGATORY NO. 6: State the amount of the subject account that Defendant admits is due and owing. RESPONSE: Defendant denies owing the plaintiff any portion of the alleged debt. Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 7: State the date that the defendant made his/her last paymnet on the subject account. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 8: State the amount that the defendant paid in his/her last payment RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 9: State the date that Defendant defaulted on the subject account. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 10: State the date that the defendant made the last charge on the subject account. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 11: If the defendant contends that there is no amount that is due and owing, please provide all specific facts that support the position that there is no amount that is due and owing on the subject account. RESPONSE: Plaintiff has offered no evidence that can be authenticated and verified to be true and accurate that would prove the alleged amount the plaintiff seeks to recover. Defendant further denies owing the plaintiff any portion of the alleged debt. INTERROGATORY NO. 12: State the date of the last payment the defendant made on the account to any entity. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 13: State all persons who used the account that is the subject of this lawsuit; state the name of all persons who has authority to use the account; state the name of any person who used the account without authority. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 14: State the balance that Defendant believes is due on the account that is the subject of this litigation and explain how such balance was calculated. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 15: If Defendant has refused to admit that Midland Funding LLC is currently the owner of the account, state the facts on which Defendant bases that refusal to admit. RESPONSE: 1) Plaintiff has not established that they own the alleged debt; strict proof is required to establish standing to sue. 2) Plaintiff has provided no evidence that they have any rights of assignment; defendant requires strict proof in the form of a contract that states such. 3) Plaintiff has offered no evidence that the alleged debt was purchased by them; defendant requires strict proof of such. 4) No debtor, creditor relationship exists; defendant requires strict proof of such. 5) Plaintiff has not offered any proof, in the form of a contract that would prove the plaintiff retains the right to bring an action on the alleged debt; defendant requires the plaintiff present the contract that proves such. INTERROGATORY NO. 16: If Defendant refuses to admit that he/she is indebted to Plaintiff, state the facts on which Defendant bases that refusal to admit. RESPONSE: 1) Plaintiff has not established that they own the alleged debt; strict proof is required to establish standing to sue. 2) Plaintiff has provided no evidence that they have any rights of assignment; defendant requires strict proof in the form of a contract that states such. 3) Plaintiff has offered no evidence that the alleged debt was purchased by them; defendant requires strict proof of such. 4) No debtor, creditor relationship exists; defendant requires strict proof of such. 5) Plaintiff has offered no evidence that would prove the accurateness of the accounting of the alleged debt; defendant requires strict proof of such. 6) Plaintiff has not offered any proof, in the form of a contract that would prove the plaintiff retains the right to bring an action on the alleged debt; defendant requires the plaintiff present the contract that proves such. INTERROGATORY NO. 17: If Defendant refuses to admit being indebted on the subject account to any entity, state the facts on which Defendant refuse to admit. RESPONSE: Defendant cannot identify the information requested as the information requested is not within the answerer’s personal knowledge or records. INTERROGATORY NO. 18: If Defendant is disputing only a portion of the account, please identify which portion of the subject account is disputed and which portion of the subject account is not disputed. RESPONSE: Defendant does not have records which would enable him to respond. Thanks in advance for any input!