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  1. 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.