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  1. Hello Everyone I firstly wanted to say THANK YOU ALL for this amazing forum. Because of you guys I now have the knowledge to take on these jerks! I'm in the discovery phase of my case, and I wanted to check with you all on the wording of my documents and also get help with being 'disrespectfully respectful' in my interrogatories haha. This is actually the second time PRA is suing me for the same debt, which I wasn't sure they could do because of res judica. But because they just sell it to other JDB's apparently the cycle can just continue on and on. Blehhhhh. So in my answer to PRA, I chose to deny everything. I also didn't give any affirmative defenses. For the Request of Admission, I denied all the allegations because they haven't proven standing/ownership of the account. All they sent were billing statements with my name and former address showing a payment that was made on 11/25/2012, along with one other billing statement with the new outstanding balance. From what I'm seeing, this is pretty standard for some cases, as that's usually all they have. I already sent a BOP Via CMRRR and that's what they sent me in response (two billing statements), even though I also asked for the contract that proves their ownership of the alleged debt and so far have received nothing. I'm working on my own Discovery and would like to send it at the same time as my responses to their Discovery. I still have two weeks before the deadline but If I can get this done I'll send it first thing Monday morning. Here's what I have for my Response to Request for Production of Things: Their requests: 1. All correspondence, whether original or copies, sent by you to Plaintiff PRA or to GE CAPITAL RETAIL BANK and/or to any collection agent or agency purporting to act on behalf of PRA or GE CAPITAL within the past 5 years regarding any problem with your former GE CAPITAL credit account number 60xxxxxx 2. All correspondence, whether original or copies, sent to you by plaintiff PRA or by GE CAPITAL and/or by any collection agent or agency purporting to act on behalf of PRA or GE CAPITAL within the past 5 years regarding any problem with your former GE CAPITAL credit account number 60xxxxxxx 3. Copies of each canceled check, money order receipt, bank account debit and other similar evidence of payment for the last payment made by you or which was made on your behalf on your former credit account number 60xxxxx with GE CAPITAL. (If you cannot find a copy of the last payment, send a copy of the last payment you are able to locate. 4. Any and all documents supporting the affirmative defenses alleged by you in this action 5. Any and all documents supporting any and all of your general or specific denials of PRA allegations in this action. RESPONDING PARTY hereby answers PROPOUNDING PARTY’s Request for Production: RESPONSE TO REQUEST FOR PRODUCTION NUMBER  1   : After diligent search and reasonable inquiry in finding requested items, defendant is unable to comply because defendant has none at this time, but if any become known to the defendant during the proceedings the defendant reserves the right to present these documents at such time RESPONSE TO REQUEST FOR PRODUCTION NUMBER   2   : After diligent search and reasonable inquiry in finding requested items, defendant is unable to comply because defendant has none at this time, but if any become known to the defendant during the proceedings the defendant reserves the right to present those documents at such time RESPONSE TO REQUEST FOR PRODUCTION NUMBER   3   : Objection. Over burdensome and oppressive. Locating such documents will cost $20/hour for bank to locate evidence of payment among over four years of bank records, as well as the incurring costs for copies of each statement. RESPONSE TO REQUEST FOR PRODUCTION NUMBER   4   : After diligent search and reasonable inquiry in finding requested items, Defendant is unable to comply with request because defendant has none, as no affirmative defenses were given. If any become known to the defendant during the proceedings the defendant reserves the right to present these documents at such time RESPONSE TO REQUEST FOR PRODUCTION NUMBER   5   : After diligent search and reasonable inquiry in finding requested items, Defendant is unable to comply with request defendant has none. If any become known to the defendant during the proceedings the defendant reserves the right to present these documents at such time The tricky part for me is answering their interrogatories without giving them any ammo. Their Interrogatories: 1. Did you ever submit a request for a credit account to GE CAPITAL RETAIL BANK? 2. Did GE CAPITAL issue a credit account number 60xxxxxx in your name? 3. State the approximate date you opened the credit account (for the purpose of these interrogatories, the credit account shall mean credit account issued to you by GE CAPITAL account number 60xxxxxx). 4. Identify (for the purpose of these interrogatories, identify shall mean to state the name, address, and telephone number) each and every person other than yourself who has ever had possession of any credit card for the credit account. 5. identify each and every person who you ever authorized to use the credit account 6. did you use the credit account? 7. Is $1,5XX.XX, the amount set for in the complaint in this case as the sum owed as of January 19, 2016, your balance due as of that date on the credit account? 8. If you do not agree that $15XX.XX, the amount set forth in the complaint in this case as the sum owed, is your balance due as of January 19, 2016 on the credit account, state all facts upon which you base your denial that the sum of $15XX.XX is your balance due as of January 19, 2016 on the credit account. 9. Did you ever report to GE CAPITAL (for the purposes of these interrogatories, GE CAPITAL shall mean and refer to PRA and/or its predecessor, GE CAPITAL, and/or any collection agent or agency purporting to represent PRA or GE CAPITAL, as to this account) that the credit card for the credit account was lost or stolen? 10. Did you ever report in writing to GE CAPITAL or PRA that there was any problem with the credit account which problem remains unresolved? 11. Did you receive periodic statements from GE CAPITAL regarding the credit account? 12. State the approximate date of your last payment to GE CAPITAL on the credit account. 13. Have you ever corresponded with GE CAPITAL in writing regarding the credit account? 14. Have you ever corresponded with PRA in writing regarding the credit account? 15. State all facts upon which you base your denial of the complaint in this action. 16. State all facts upon which you base each affirmative defense to the complaint in this action Here's what I have so far for my response to their interrogatories: Interrogatory 4: N/A Interrogatory 5: N/A Interrogatory 9: Objection. Argumentatuve and lacking in foundation, as this question assumes facts that are not in evidence. There is nothing in the record that supports the claims made in Plaintiff's question, and these claims cannot be assumed without unfairly prejudicing the Defendant. Interrogatory 10: OBJECTION Argumentative and lacking in foundation, specifically that any such billing statement was received. Again, thank you all from the bottom of my heart for creating this site. I can't thank you enough!