Plaintiff's First Request For Admissions

[INTHERED]

Hello, I started on some responses and wanted to check to see if I was headed in the right direction or if I had the right idea.

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1. That you admit that this is an action for damages properly before this court as alleged in Paragraph One of Plaintiff's Complaint.

At this time defendant admits nothing.

2. That you admit that you applied for a credit card account with the original credit grantor.

Defendant denies ever applying for a credit card account with the original credit grantor.

3. That you admit that the original credit grantor established a credit card account in your name bearing the account number XXXXXXXXX.

Defendant denies that the original credit grantor established a credit card account in my name bearing account number XXXXXXXXX. Defendant has no knowledge of mentioned account. Nor has any proof been furnished.

4.That you admit that you were issued a credit card or cards by the original credit grantor.

At this time Defendant admits nothing. Defendant denies that he was issued a credit card by the original credit grantor.

5. That you admit that either your or others authorized by you used the credit card account and/or the credit card or cards issued by the original credit grantor and incurred charges thereunder.

Defendant denies all claims.

6. That you admit that you received the original credit card agreement, a copy of which is attached to Plaintiff's Complaint.

Defendant denies such claim, Defendant has no knowledge of said credit card account or credit card agreement.

7.That you admit that the copy of the credit card agreement attached to Plaintiff's Complaint is a true and correct copy of the original of said agreement that was sent to you.

Defendant denies such claim.

8. That you admit that you have failed to make payment when due on the credit card account.

9. That you admit that Plaintiff purchased and owns your credit card account and succeeded to all the rights of the original credit grantor.

10. That you admit that you now have due and owing to the Plaintiff the amount as correctly stated in Plaintiff's Complaint.

11. That you admit all conditions precedent to bringing this action have occured or have been waived.

12. That you admit that Plaintiff is obligated to pay its attorney a reasonable fee for their services.

13. That you admit that credit card agreement provides for the recovery of attorney's fees from the Defendant.

[merrybucks]

You could also use as an answer "defendant has insufficient information at this time to admit or deny."