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Found 3 results

  1. BB&t is suing me. I filed my answer mostly no knowledge and therefore deny and included affirmative defenses. Now they have filed a motion to strike my affirmative defenses as well as interrogatories, request to produce, certificate of completion, request for admissions. I have no idea what to do now. I don’t want to loose and incur more legal fees?
  2. Okay Folks, So here's a question for you. I've been searching the forums for what's allowed to be asked in interrogatories. It's my understanding that Discovery in General can be very broad. In this case, I am the Plaintiff and ACME Collections is the Defendant in a TCPA case. I noticed requesst in their Interogatories for very specific information that doesn't really have relavance to the case. I know that people often object to requests for admissions or interogatories in Discovery, but are you really required to answer detailed questions like: List every place that Weary Traveler has ever worked, since the beginning of time, including dates of employement, job position and title, employers phone numbers and your salary, and reason for leaving your job.List ever place Weary Traveler went to school, every bit of training or vocation you ever learned (does this include beer pong?), every degree you ever got, every date you attended, when you graduated.Identify all other law suits or court proceedings you've been involved inIdentify any other collection accounts or Creditors you ever have had contact with in the last X years.Identify any criminal record you've ever had, including any jail or prison you've ever been in...LOL? wow.Identify your home and cellular telephone numbers and who the provider is
  3. Trying to understand how to respond to interogatoies request for admissions and production in a fcra credit pull case Some of the request seem redundant not asking for actual damages in case not requesting experts for a credit pull case also i think asking for my credit report is not required, since thats what i am suing about asking about jail or prison records and questions is irrelavant to case Exhibit A i never recieved in mail recieved thru email from attorney a piece of mail they say was sent 2 years ago Exhibit B was recieved thru email in a response to a intent to sue letter DEFINITIONS A. “Issuer” refers to Citibank (South Dakota), N.A. B. “Account” or “the Account” refers to the Visa Account ending in 4227 issued by Citibank, N.A. in the name of Philip York. C. “Card” or “the Card” refers to the Visa credit card that was issued on the Account. D. “Plaintiff,” “you,” “your,” or “yours” refers to Philip York. E. “Defendant” refers to LTD Financial Services, L.P. and encompasses any person, employee, or other entity authorized to act on behalf of LTD Financial Services, L.P. these are some interogatories and admissions i have been asked below and not sure how to respond INTERROGATORIES AND REQUESTS Interrogatory No. 1: State every address at which Plaintiff has resided or that Plaintiff has used for any business purpose from January 1, 2009, to the present. RFA No. 1: Plaintiff received the Card. RFA No. 2: Plaintiff activated the Card. RFA No. 3: Plaintiff used the Card. Interrogatory No. 2: If your answer to RFAs 1, 2, or 3 was anything other than an unqualified admission please identify all persons whom you contend or believe may have activated or used the Card. RFA No. 4: Plaintiff applied for issuance of the Account. RFA No. 5: The Account was issued to Plaintiff. RFA No. 6. Plaintiff agreed to pay all charges incurred on the Card. RFA No. 7. Plaintiff agreed to pay all charges incurred on the Account. Interrogatory No. 3: If Plaintiff denies having agreed to pay for all charges incurred on the Card or the Account state Plaintiff’s understanding of his obligations upon using the Card or the Account. RFP No. 1: If Plaintiff denies having received the Card please produce all correspondence between Issuer and Plaintiff. RFP No. 2: If Plaintiff denies having received the Card please produce Plaintiff’s checking account records for the period from January 1, 2008 through and including September, 2009. RFA No. 8. Plaintiff received the attached Exhibit A. Interrogatory No. 4: If Plaintiff denies having received the attached Exhibit A then please state the address at which Plaintiff was residing on August 20, 2010. RFA No. 9. Paragraph 21 of Plaintiff’s Complaint describes the conduct of Defendant on which Plaintiff’s suit is based. RFA No. 10. The two credit inquiries described in Paragraph 21 of Plaintiff’s Complaint are the only actions of Defendant forming the basis of Plaintiff’s claim. RFA No. 11: Plaintiff incurred charges on the Account. RFA No. 12: There were no charges on the Account that were not authorized by Plaintiff. RFA No. 13: By accepting each such charge under the terms of the agreement applicable to the Account Plaintiff became bound to pay the amounts of such charges. Interrogatory No. 5: If Plaintiff denies having accepted each charge on the Account, identify each charge on the Account that Plaintiff disputes and state the factual basis of each such dispute. RFA No. 14: Until at least the date that the Account was charged off to profit and loss Issuer sent to Plaintiff on a monthly basis a statement of charges and balance due on the Account. RFP No. 3: Please produce all billing statements to Plaintiff which pertain to or refer to the Account. Interrogatory No. 6: If Plaintiff’s response to RFA No. 14 was anything other than an unqualified admission state the factual basis of any such refusal to admit. RFA No. 15: Plaintiff 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. RFP No. 4: Please produce true copies of all correspondence from Plaintiff to Issuer disputing any billing statement on the Account, together with proof of sending and receipt of such correspondence. RFA No. 16: Plaintiff failed to pay all of the charges on the Account. RFP No. 5: If Plaintiff’s response to RFA No. 16 was anything other than an unqualified admission please produce true copies of all payments made on the Account. RFA No. 17: In 2010, the Issuer engaged Defendant to collect the Account, Interrogatory No. 7: If Plaintiff’s response to RFA No. 17 is anything other than an unqualified admission state the facts on which Plaintiff bases his refusal to admit. RFP No. 6: If Plaintiff’s response to RFA No. 17 is anything other than an unqualified admission please produce true copies of all documents on which Plaintiff bases his refusal to admit. RFA No. 18: The attached Exhibit A is a true copy of Defendant’s correspondence to Plaintiff dated August 20, 2010. RFA No. 19: The attached Exhibit B is a true copy of Defendant’s correspondence to Plaintiff dated October 5, 2012. Interrogatory No. 8: State all dates on which Plaintiff has been in a state or federal jail or prison from January 1, 2008, to the present. Interrogatory No. 9: For the period from January 1, 2004 to the present state each crime of which Plaintiff has been convicted, whether through bench trial, jury trial, or plea bargain. RFP No. 7: For the period from January 1, 2004 to the present state each crime of which Plaintiff has been charged, other than parking and speeding offenses. RFP No. 8: Produce all documents evidencing any credit denial or credit impairment as a result of the conduct described in Paragraph 21 of Plaintiff’s Complaint. Interrogatory No. 10: If Plaintiff is claiming actual damages in this case please: a. state every dollar of actual damages that Plaintiff claims and explain how all such damages were calculated; b. identify all witnesses to such actual damages; and c. identify all documents that evidence or relate to such actual damages. RFP No. 9: If Plaintiff is claiming actual damages in this case please produce the documents that evidence or support every dollar of actual damages that Plaintiff claims. Interrogatory No. 11: 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. Interrogatory No. 12: 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. RFP No. 10: With regard to each expert identified in response to Interrogatory No. 12 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. Interrogatory No. 13: Identify all persons whose mental impressions or opinions have been reviewed by any person whom you may call as an expert witness at trial. RFP No. 11: With regard to each person identified in response to Interrogatory No. 11 please produce: a. the person’s resume or curriculum vitae; b. all notes of such person that were reviewed by any expert identified in response to Interrogatory No. 13; c. any reports prepared by such person that were reviewed by any expert identified in response to Interrogatory No. 13; d. all documents and materials reviewed or relied upon by such person in preparing any such report; and e. all correspondence between you or your attorneys and each such expert. RFP No. 12: Please produce all correspondence between Defendant (or any of its attorneys) and Plaintiff (or any of Plaintiff’s attorneys). RFP No. 13: Please produce all correspondence between Issuer and Plaintiff. RFP No. 14: Please produce all statements of Defendant or any of Defendant’s attorneys. RFP No. 15: Please produce all witness statements pertaining to this litigation. RFP No. 16: If Plaintiff is seeking mental anguish damages from Defendant, please produce: a. the documents evidencing the specific acts or omissions of Defendant that Plaintiff contends were the cause of such mental anguish damages; b. the documents evidencing the date(s), nature, and duration of the alleged mental anguish damages that Plaintiff contends were caused by each such act or omission; c. the documents evidencing the manner in which such alleged mental anguish caused any disruptions in Plaintiff’s daily routine; d. the documents evidencing all mental and physical health care and counseling that Plaintiff received in connection with such alleged mental anguish damages; e. the bills for all mental and physical health care and counseling that Plaintiff received in connection with such alleged mental anguish damages; f. the receipts for all medications that Plaintiff claims to have taken in connection with such alleged mental anguish damages; g. any other documents evidencing such alleged mental anguish damages; and h. a medical authorization in the form attached hereto for every mental and physical health care professional who has counseled or treated Plaintiff in connection with or as a result of such alleged mental anguish damages. RFP No. 17: If Plaintiff is seeking compensatory damages for economic or pecuniary loss from Defendant, please produce: a. the documents evidencing the specific acts or omissions of Defendant that Plaintiff contends were the cause of such alleged economic or pecuniary loss; b. the documents evidencing each component of the alleged economic or pecuniary loss that Plaintiff contends was caused by each such act or omission; c. the payroll records and any paycheck stubs evidencing any alleged loss of wages claimed by Plaintiff against Defendant; d. the canceled check, receipt, or credit card statement evidencing each such alleged economic or pecuniary loss; e. Plaintiff’s last two federal income tax returns; and f. Plaintiff’s last two state income tax returns. RFP No. 18: Please produce Plaintiff’s Trans-Union, Experian, and Equifax reports or a verified consent in the form attached authorizing Defendant to obtain copies of such reports. Interrogatory No. 14: State the amount of attorney’s fees and costs, if any, that Plaintiff is seeking in this case.