Interrogatories Answers.Are mine ok?

[bellasummer]

I answered the interrogatories questions.Can you review my answers and tell me if I was horribly wrong on any of them.I have already wrote them in,If it's horrible, I could retype the whole thing if necessary..Thanks!!!

Interrogatories:1-Set forth in detail each defense which the defendanat has to the above-entitled cause of action, and in detail give the factual basis for each,setting forth dates,places,names and addresses of persons present,or involved in conversations:

ANS-Deny, the plaintiff has made demand for an alleged debt.

2-Do you admit that you owe the plaintiff the amount of $3,491.98 on acct number XXXXXX as set forth in the plaintiff's complaint?( If the answer is in the negative,set forth reason therefore.

ANS- Denied. Plaintiff has made demand for an alleged debt.

3-What if any credits,allowances,deductions do you claim to be entitled to which not have been given by the plaintiff in regards to the account which is thr subject matter of the complaint.Specify amount,include cancelled checks.

ANS-Deny,Plaintiff has made a demand for an alleged amount due.Defendant doesnt have cancelled checks/reciepts for this alleged debt.

4-Did you recieve monthly preiodicals,statements,from the bank on acct number xxxxxxxxx setting for the amount due?

ANS-Deny, Plaintiff has made demand for an alleged amount due.There is no proof of this acoount.

5-If the defendant claims any error or accuracy in the dollar amount claimed to be owing in the plaintiff's complaint,which is not entitled by the ongoing interrogatories,identify;

ANS-Deny,plaintiff has made demand for an alleged amount due.

6-Please list all addresses,which you resided at from 6/1/01 to 10/31/07.Electric bills, copies of mortgage,drivers liscence

ANS: Object Past addresses, electric bills,drivers liscence arent relevant to the case at issue.

7- Did you utilize a checking account in 2007 If yes,please provide

The name of the bank,acct number,bank statements..

ANS(This is important to state correctly becasue i was harrassed so much last year at work that I made a payment that is on my bank statements from last year.)

Object:Not relevant to the case at issue

8-Identify all persons you expect to call as factual witnesses and expert witnesses at trial.State the subject matter

ANS: Presently unaware of such responsive witnesses however, discovery is just beginning,and I reserve the right to introduce any susequently discovered documents or witnesses at trial.

Request for Admissions:

1-You applied for credit priveliges with US Bank/

ANS- Deny, the defendant denies Plaintiff's request for Admission #1

2-You promised to pay for the purchases made on US Bank Acct number XXXX?

ANS- Deny,the defendant denies Plaintiff's request for admission #2.

3-You were extended credit privelages under US Bank under acct number XXXXX

ANS-Deny,Defendant denies Plaintiff's request for admission #3.Defendant is without knowledge demands proof.

4- You made purchases,cash advances utilizing bank number XXX

ANS- Deny,Defendant denies Plaintiff's request for admission #4.Defendant is without knowledge demands proof.

5-You recieved monthly statements concerning US bank specifying previous balances,new purchases,finance charges.

ANS-Deny,Defendant denies Plaintiff's request for admission #5.Defendant is without knowledge demands proof.

6-You did not contest the amounts reflected on the statements within 60 days provided by the fair credit billing act?

ANS-Deny,Defendant denies Plaintiff's request for admission #6.

7-Bank # XXX which is the subject of this duit,went into default for non-payment?

ANS-Deny,Plaintiff has made a demand for an alleged amount due.Defendant denies Plaintiff's request for admission #7.

8-The sum of $3,451.98 due and owing on US Bank acct number in this complaint is accurate?

ANS-Deny,Defendant is without knowledge,demands proof.Defendant denies Plaintiff's request for admission #8.

9-You agreed to pay attorney fees in the event the account which is the subject matter of this suit was reffered to an attorney for collection?

ANS-Objection,the plaintiff has not specifically identified significant detail to allow the defendant to properly admit or deny. The request is denied.

10-The balance due as set forth in the last monthly statement sent on US Bank number XXXX before referral to collection in the amt of 3430.27 is in fact due and owing?

ANS- Defendant denies Plaintiff's request for admission #10.

11-Do you admit that Livingston Financial is the owner of US Bank number XXXXXX?

ANS-

Deny,the defendant at this time is without knowledge to form a belief as to the truth of this allegation.Defendant denies Plaintiff's request for admission #11.

[swirlgirl]

To be honest, a lot of your answers do not make sense and are not worded properly. If you file this, the plaintiff might go ahead and file a Motion for Summary Judgment.

For instance , you repeatedly use: "Denied. Plaintiff has made demand for an alleged debt." What does that mean?