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Answering a request for discolure

chris l

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I need some advice on answering request for disclosure/request for admission/interrogatories.

I am in Texas and a law firm has filled suit against me for a cc debt. I filed and answer. They requested a summer judgment and I file a request for dismissal which I think will win.

What’s best way to answerer this. In the request for admission, they pretty much ask did you open the account and did you agree to pay it.

I do plan to send them a request for disclosure as well.


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1. Who is suing you? Mccleskey, Harriger, brazil & graff

2. For how much? $2500

3. Who is the original creditor? First national bank of Omaha

4. How do you know you are being sued? I was served

5. How were you served? Were you served? Was properly served in person

6. What was your correspondence (if any) with the people suing you before you think you were being sued? Requested debt validation twice the year before. They responded with an in house produced acct stmt. They sent another collection letter this year and I failed to send another validation letter. The attorney that is sueing me sent a collection letter and I sent them a validation letter and they never answered.

7. Where do you live? TX

8. When is the last time you paid on this account? 4-5-04

9. What is the status of your case (if anything has been opened)? You can find this by a) calling the court or B) looking it up online (many states have this information posted daily). I just submitted documents to have the request for a summary judgment dismissed and I should be successful.

10. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) Just the collection agency

11. Did you request debt validation before the suit was filed? If not, don't bother doing this now. Yes. To the collection agency and the attorney they using.

12. Does your summons require a response? (Look hard!) If you don't get a questionnaire with your summons, you are still probably required to answer it in writing. If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? Responded to the summons with a general denial. Just received a packet of stuff from the atty. A request for Disclosure, Plaintiffs request for admission, plaintiffs first set of interrogatories to defendant and plaintiffs request for production of documents and tangible things

13. What evidence did they send with the summons? An affadavit? A statement from the OC? Anything else they attached as exhibits? Just an in house produced affidavit.

14. What is the SOL on the debt? To find out: 4 years

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