Comments on my discovery response?

[codename_fortyseven]

Ok, most folks know about my issue with a phone company and inquiries. I am suing, and their lawyer had some questions in discovery.

I am almost ready to reply, but I wanted to run it past the folks here first.

Request for production:

1. Credit report

-already faxed it

2. All documents that support allegation defendent illegally accessed my credit report.

- Should I include the FTC letters with this? I am thinking yes, as I definately don't want these excluded at trial. I think also the initial bill I have where they state that they are billing me in advance supports it as well. Anything else?

3. Produce copies of documents from defendent that domonstrate/support claim

-Kinda redundant, but again I am thinking the initial bill, no?

4. Produce all documents containing communication between me and defendent

-I have several emails that I think might be interesting to read. I also have my initial "I'm pissed off letter" I sent them.

Overall- This pertains to paper documents only, correct?

I also have some fun, fun recordings that might prove interesting.

Interrogs

1. State contaact info of all people who have relevant knowledge of any facts pertaining to lawsuit. Interrog also requests info regarding each and every individual I have discussed the claims with.

-I know of one person at the company that may have some info, and that's about it. As far as naming every person, I am going to object on the grounds that it is irrelevant to the case.

2. State contact info for anyone I expect to call to testify at trial.

-it's just me, no witnesses or experts

3. If I know, heard, believe any person affiliated with company has communicated with anyone ever in any medium that would be related to trial, state person, time, date, etc.

Seems to me the relationship between the utility and the credit bureau may be relevant. Can't think of anything else.

4. Identify all communication between myself and the defendent, identify person involved, etc..

I do have some recordings of myself and the company. I essentially sign up for service and it serves as proof that they never disclose the fact that they intend to pull a credit report. When they ask for my SSN the say it is for "identity verification" Wouldn't that be obtaining consumer info under false pretenses? Section 619, I believe?

Thoughts, inputs appreciated!

[admin]

2. All documents that support allegation defendent illegally accessed my credit report.

- Should I include the FTC letters with this? I am thinking yes, as I definately don't want these excluded at trial. I think also the initial bill I have where they state that they are billing me in advance supports it as well. Anything else?

Case law? Preferrably federal or in your state.

4. Produce all documents containing communication between me and defendent

-I have several emails that I think might be interesting to read. I also have my initial "I'm pissed off letter" I sent them.

Overall- This pertains to paper documents only, correct?

I also have some fun, fun recordings that might prove interesting.

Email is good. Also, did you keep a log of conversations? This is admissible as part of your testimony.

1. State contaact info of all people who have relevant knowledge of any facts pertaining to lawsuit. Interrog also requests info regarding each and every individual I have discussed the claims with.

-I know of one person at the company that may have some info, and that's about it. As far as naming every person, I am going to object on the grounds that it is irrelevant to the case.

Yes, completely irrelevant.

3. If I know, heard, believe any person affiliated with company has communicated with anyone ever in any medium that would be related to trial, state person, time, date, etc.

Seems to me the relationship between the utility and the credit bureau may be relevant. Can't think of anything else.

I think this falls under "irrelevant"

4. Identify all communication between myself and the defendent, identify person involved, etc..

I do have some recordings of myself and the company. I essentially sign up for service and it serves as proof that they never disclose the fact that they intend to pull a credit report. When they ask for my SSN the say it is for "identity verification" Wouldn't that be obtaining consumer info under false pretenses? Section 619, I believe?

It's gotta fall under "firm offer of credit, insurance, employment or court-ordered". That doesn't seem relevant here.

[codename_fortyseven]

I am hurting for any case law regarding inqs. Does anyone have any idea of them?

On point 4 of discovery, I do have the recordings, which I could transcribe, and I have some of the times/dates of the conversations.

They won't be getting any info on who I spoke with.

I think I might mention some relationship between the company and the CB's, but I'll follow that up in MY discovery request

Regarding point 4 of the interrogs, what falls under "the firm offer of credit?" I am a little confused there.

Also, can you think of any good stuff to request in my discovery request? I'll post that a little bit later. I am also thinking of sending my request for settlement talk with my discovery request. I already asked for a deletion of all inqs and 1k to settle.