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Filing for Discovery

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When I send a letter to Midlands atty. for discovery can I list specific documents I want? The atty. I consulted this week said just to send them a letter stating "to produce a copy of all statements written, oral or otherwise in your possession". Can I elaborate on this like asking for the contract assigning it to Midland, and I want a copy of the card agreement? Its been almost 5 yrs. and the atty. I spoke to thought the original creditor uses a Delaware SOL. He said if they can't produce the documentation I can bring a motion to preclude the evidence.

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