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  1. I am being sued by Portfolio Recovery Associates, LLC with Hunt & Henriques representing them. I am in San Bernardino County, California. They claim that I owe them ~$6,000, but I do not recognize them as the owners of the debt owed. I replied to their summons with a general denial (PLD-050), as their “proof” was not validated, and mailed it along with POS-030 (unsigned). I filed a copy of the PLD-050 and POS-030 with the court, and got a stamped copy for myself. Four days ago I received something new in the mail: a Plaintiff's Specially Prepared Interrogatories, a Requests for Admission, and a Demand for Production of Documents. They say that these documents must be responded to within 35 days. Out of the three, I am primarily concerned about the Prepared Interrogatories, as I am unsure how I am supposed to respond to them when I don't even acknowledge that they are the debt owners. Below I will list the questions verbatim, minus any personal information. Prepared Interrogatories Interrogatory Number 1: Did you every submit a request for a credit account to CITIBANK, N.A. Interrogatory Number 2: Did CITIBANK, N.A. Issue a credit account number [Number Omitted]in your name? Interrogatory Number 3: State the approximate date you opened THE CREDIT ACCOUNT (for the purpose of these interrogatories, THE CREDIT ACCOUTN shall mean credit account issued to you by CITIBANK, N.A. Account number [Number Omitted]. Interrogatory Number 4: IDENTIFY (for the purpose of these interrogatories, IDENTIFY shall mean to sate the name, address, and telephone number) each and every person than yourself who has ever had possession of any credit card for THE CREDIT ACCOUNT. Interrogatory Number 5: IDENTIFY each and every person who you every authorized to use THE CREDIT ACCOUNT. Interrogatory Number 6: Did you use THE CREDIT ACCOUNT. Interrogatory Number 7: Is [Number Omitted], the amount set forth in the complaint in this case as the sum owed as of [Date Omitted], your balance due as of that date on THE CREDIT ACCOUNT? Interrogatory Number 8: If you do not agree that [Number Omitted], the amount set forth in the complaint in this case as the sum owed, is your balance due as of [Date Omitted] on THE CREDIT ACCOUNT, state all facts upon which you base your denial that the sum of [Number Omitted] is your balance due as of [Date Omitted] on THE CREDIT ACCOUNT. Interrogatory Number 9: Did you ever report to CITIBANK, N.A. (for the purposes of these interrogatories, CITIBANK, N.A. Shall mean and refer to Portfolio Recovery Associates, LLC, and/or its predecessor, CITIBANK, N.A., and/or any collection agent or agency purporting to represent Portfolio Recovery Associates, LLC or CITIBANK, N.A., as to this account) that the credit card for THE CREDIT ACCOUNT was lost or stolen? Interrogatory Number 10: Did you every report in writing to CITIBANK, N.A. Or Portfolio Recovery Associates, LLC that there was any problem with THE CREDIT ACCOUNT, which problem remains unsolved? Interrogatory Number 11: Did you receive periodic statements from CITIBANK, N.A. Regarding THE CREDIT ACCOUNT? Interrogatory Number 12: State the approximate date of your last payment to CITIBANK, N.A. on THE CREDIT ACCOUNT. Interrogatory Number 13: Have you ever corresponded with CITIBANK, N.A. In writing regarding THE CREDIT ACCOUNT? Interrogatory Number 14: Have you ever corresponded with Portfolio Recovery Associates, LLC in writing regarding THE CREDIT ACCOUNT. Interrogatory Number 15: State all facts upon which you base your denial of the complain in this action. Interrogatory Number 16: State all facts upon which you base each affirmative defense to complain in this action. [Please note that I did not use any affirmative defense when filing my general denial.] Now, as for the Requests for Admission (DISC-020), it is basically all of the above questions rewritten to be statements that imply my guilt in each one, with a area at the bottom for me to sign agreeing to their claims. I have no intention on signing this, but do I still need to reply to it? And finally, the Demand for Production of Documents. They're asking for any and all paperwork I have associated with CITIBANK, N.A., Portfolio Recovery Associates, etc, but I no longer have any in my possession. Is there a particular form I need to fill out to respond to this? If so, which? Thank you all for your help, it's much appreciated.