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Discovery/Interagatory response question(s) -


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Interrigatories - (answers in bold, do they look correct?)

"Attach to your answers to these intergogatores a copy of each and every document, writing, paper or letter which you intend to utilize as a basis or ground for any defense in thsi action, or in the alternative, state at lenght and verbatim the content of each and every document [...] additionally stating the date and circumstances of preparation or reciept of such item."

Objection, Overly Broad and Burdensome ?

If you have not fully admittend any one or more of the requests for admissions, for each request, stathe the reasons you havent admitted it.

Objection Overly broad and burdensome, defendant has already answered these questions in the aforementioned request for admissions.

State in specific detail why you deny that you owe the plaintiff the amount sought

Plaintiff has offered no evidence, signed affidaviits or witnesses attesting tto the validity of the claims.

State fully the factual basis for each and every defense which you have asserted or will assert in this action

Objection - overly broad and burdensome, to the extent that an answer is required, the defendant states that the plaintiff has provided no evidence ...

Describe all instances in which you have been charged with and pled guitly to or have been convicted of a crime where the crime was punishable ...

Objection - Irrelivant to the litigation at hand and is unlikely to lead to admissable evidence

(in fact, there are none, but I find this question revolting - i'll likely use this response for a couple of other similar questions)

How does one answer this request for admission?

Do you admit that you have no evidence to support the allegations, claims and defenses contained in your answer to the complaint?

Is a simple "no" or "Denied" enough?

Under the request for documents - they are asking for records/billing statements that i have already denied having - is there a simple statement that says that?

Additionally - are there any good examples of Requests for Admissions or interogatories to thow at the plaintiff? Should I just turn many of there requests for admissions on them? (Do you admit that you have no evidence that shows that the defendant ...)? Or is that considered bad form?

Thanks!

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