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  1. This isn't my first rodeo. I have a thread here for my own case (which I won) and am now at the point of filing for Proposed Judgment of Dismissal to get my costs back. Thanks to Calawyer and RyanEx for your help with the drafts! Now to the point why I'm posting. Midlund Funding is suing Hubby for a debt that's smaller than what I had been sued for by about $200 and change. He has sent a BoP, a MTC when they responded with almost nothing, and filed a GenDen, gotten a Trial Setting Conference date, and he's in the middle of Discovery. They've responded to his First Set RFP with more paperwork than they had to the BoP and MTC. This time they've included copies of letters he sent to get VALIDATION (not verification) of the alleged debt, and when they failed to respond, he wrote them another letter with the same request, and they, again, failed to respond. This happened at the beginning of this year, according to the dates. Now the kicker: they've included a copy that they've notified him that they bought the account (7/1/2016 - never received), a copy that Hunt & Henriques that they're handling the Midland account (10/29/2015 - never received) and a copy of their "Intent to Sue" dated 12/22/2015 (received). We did NOT receive the first two letters (and it's questionable they even sent these) but Hubby did receive their letter (along with family Christmas cards) for their intent to sue. Hubby sent a DV on 01/07/2016, which they didn't respond to. When no response came, he got nervous and sent another DV on 03/21/2016, which they also ignored (my guess is, they were planning to sue all along). My question: HAVING THESE COPIES, HOW DOES HE RESPOND TO THEIR DISCOVERY, SPECIFICALLY THE NO. 14 and NO. 15 of the ROGS? No. 14: Have you ever corresponded with Midland Funding LLC in writing regarding THE CREDIT ACCOUNT? Should he here mention the DV letters he's sent since they have copies? No: 15: State all facts upon which you base your denial of the complaint in this action. Should he just respond with "Based upon the foregoing objection, defendant responds as follows: DENIED." I will appreciate any and all help. He must mail back the responses to plaintiff's ROGS, RFAs, and RFPs by Friday, November 4 which marks the 35 days after they sent their Discovery, but I don't want him to be late. PLEASE HELP ASAP.
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