ladybug412 Posted November 7, 2009 Report Share Posted November 7, 2009 (edited) Hi. We need a little help with our response to some interrogatory questions. We are being sued by a JDB and we live in Oklahoma.Interrogatory - If you believe that the venue of this action is not proper in the county in which this suit was filed, state the factual basis of any such belief.Is this a trick question? Or just a simple verification of venue? This JDB has named two different balances due on the alleged account they on which they filed suit. In Oklahoma, small claims court goes up to $6,000. Are they trying to get us to acknowledge a higher balance for this alleged debt? Are we paranoid? Interrogatory - If you deny any of the Requests for Admissions, state with specificity the truth of the matter as you allege.Interrogatory - If you deny any of the Requests for Admissions, identify each and every document which you assert supports the truth of the matter as you allege.Interrogatory - If you deny any of the Requests for Admissions, identify each and every person who has any knowledge whatsoever of the truth of the matter as you allege, or whose testimony would tend to corroborate your statement as to the truth of the matter as you allege.We're unsure of how to answer these three interrogatories. We didn't deny any of the Requests for Admissions, we did object to most of them and may admit one with a qualifying statement. Should we pretty much just say that? Edited November 9, 2009 by ladybug412 Link to comment Share on other sites More sharing options...
ladybug412 Posted November 7, 2009 Author Report Share Posted November 7, 2009 (edited) Thank you in advance for your help. Edited November 9, 2009 by ladybug412 Link to comment Share on other sites More sharing options...
ladybug412 Posted November 9, 2009 Author Report Share Posted November 9, 2009 Bump - need help with these and need to mail Monday. Thanks. Link to comment Share on other sites More sharing options...
musimann Posted November 9, 2009 Report Share Posted November 9, 2009 I would answer like this:1. Interrogatory No. X is objected by the Defendant on the grounds that it is unduly burdensome to the extent it seeks information that is not within the current knowledge of the Defendant. Without waiving his objection, the Defendant reserves the right to update this answer to this interrogatory at a later time.For the rest:Interrogatory No. X is objected by the Defendant on the grounds that it is seeking information that is premature given that the parties are in the midst of discovery and pertinent documents have not yet been produced by the Plaintiff. Without waiving his objection, the Defendant upon completion of discovery with the Plaintiff, will most definitely have defenses in this action, and will provide such defenses to the Plaintiff if asked through Discovery. The Defendant reserves the right to update this answer to this interrogatory at a later time when that decision is made. Link to comment Share on other sites More sharing options...
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