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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.