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Please help! How do I respond to these requests?


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I do not owe the debt and in response to my answer they provided me with a sleazy so-called account number and all the following questions.

What is the best way to respond to these questions? Thanks in advance for any and all input.

PLAINTIFF'S FIRST SET OF INTERROGATORIES,

REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION OF DOCUMENTS

INTERROGATORIES

Interrogatory No. 1

Please state your full name, address, date of birth, place of birth, and social security number.

Interrogatory No. 2

What is the name and address of the bank where you have your checking account?

Interrogatory No. 3

What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Interrogatory No. 4

Identify any payment that you have made to the original creditor, Credit Store, and state the date of the last payment you made to the original creditor and the amount of that payment.

Interrogatory No. 5

Identify any payment that you have made on the Account, number 9037285, and state the date of the last payment you made on the Account and the amount of that payment.

Interrogatory No. 6

What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Interrogatory No. 7

Please list the date and amount of all payments made by check, money order, banks official check or any other means, that you claim were made on the Account.

Interrogatory No. 8

Is the amount that you owe on the Account sued upon correct and, if not, what is the correct amount?

Interrogatory No. 9

If any offers of settlement were made to you on your Account, please state the name address, and phone number of the person and company who offered you the settlement and how long the settlement was good for?

Interrogatory No. 10

Please state the manner in which you paid any settlement that you allege was made (i.e. check, money order, etc.).

Interrogatory No. 11

Have you ever received a settlement letter or paid in full receipt evidencing an amount you paid toward the Account sued upon?

Interrogatory No. 12

Please provide the following information for each person you will call as a witness at the trial of the captioned matter:

1. Name, address, and telephone number;

2. Place of employment;

3. Relation to the Defendant:

4. The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Interrogatory No. 13

Please identify and describe each exhibit you will use in the trial of the captioned matter.

Interrogatory No. 14

Are you currently involved in any litigation in which you are a Plaintiff? If so, then:

1. In what court is this matter pending?

2. What is the nature of this claim?

Interrogatory No. 15

State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action.

Interrogatory No. 16

As to each defense set out in response to Interrogatory Thirteen (13), above, state the following as to notification to Plaintiff by Defendant of such defenses: (a) the date or dates when notification was given; (B) the manner in which notification was given; and © the specific party or parties to whom notification was given.

REQUESTS TO ADMIT FACTS

The Plaintiff requests that the Defendant answer the following requests to admit facts pursuant to, and in accordance with, Kentucky Rules of Civil Procedure 36. If the Defendant objects to any requested admission, the reasons therefore shall be stated. The Defendant's answer shall specifically admit or deny the requested admission, or set forth in detail the reasons why the Defendant cannot truthfully admit or deny the requested admission. A denial shall fairly meet the substance of the requested admission, and when good faith requires that the Defendant qualify an answer or deny only a part of the matter of which an admission is requested, the Defendant shall specify so much of it as is true and qualify or deny the remainder, again detailing the specificity of the denial or the part thereof

Fact No. 1

Please admit that you applied to the original creditor, Credit Store, for the account, number 9037285, in question.

Fact No. 2

Please admit that you are indebted to the Plaintiff in the amount of $1,012.56, plus any accrued interest, as shown on Plaintiffs Complaint.

Fact No. 3

Please admit that you made payment(s) on your account.

Fact No. 4

Please admit that you owe the balance on the Account to the Plaintiff.

Fact No. 5

Please admit that the correct balance is outlined in the Complaint.

Fact No. 6

Written demand for payment of the charges subject of this action was made upon Defendant by Plaintiff or Plaintiffs counsel thirty (30) days or more prior to the filing of the Complaint in this action.

DOCUMENTS TO BE PRODUCED

1. Please provide copies of any and all payments made on the account sued upon, for example, all canceled checks, money order receipts, etc., including a copy of any payment which you allege paid off or settled the account sued upon.

2. Please provide copies of any and all settlement letters or offers to settle regarding the Contract sued upon.

3. Please provide copies of any and all receipts, letters, or other information that supports your contention that the account was paid in full.

4. Please provide copies of any and all exhibits and/or evidence that you intend to introduce at trial.

5. If you are currently involved in any litigation as a Plaintiff, inside or outside of the state of Kentucky, please provide a copy of the petition for damages, including amendments and responses.

6. Please provide copies of all notice letters, collection letters, statements and charge slips in your possession on the contract sued upon.

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I don't think anyone here can help you without more information. You say you don't owe the debt, but you don't say why, so we can only make guesses. And it's obvious that only you could possibly know the answers to some of these questions.

But making some assumptions, I'll take a stab at it anyway.

I1. Provide the information asked for, but I would object to the SSN on the grounds that it is private in nature and not relevant to the litigation at hand.

I2. Responding party objects on the grounds that this information is private in nature, is not relevant to the litigation at hand, nor will it lead to the discovery of admissible evidence.

I14. Responding party objects on the grounds that this information is private in nature, is not relevant to the litigation at hand, nor will it lead to the discovery of admissible evidence.

For the rest of the Interrogatories, if this debt isn't yours, your answer will be something like "There was none."

For the Request to Admit, if this isn't yours, the answers will be "Deny."

Similarly for the Documents, "No such documents exist."

All this is assuming, of course, that these are the truth.

Regards,

DH

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