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  1. 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
  2. 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 credit
  3. 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 interrogato
  4. (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
  5. 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
  6. 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.
  7. 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 w
  8. 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 p
  9. 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.
  10. 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
  11. 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
  12. 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 a
  13. 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
  14. 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
  15. 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 af
  16. 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
  17. 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,
  18. 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 o
  19. 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 "W
  20. 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.
  21. 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
  22. 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
  23. 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
  24. 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
  25. 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 somethi