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Need help with answers in AZ


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I've searched for threads with similar situation and can't find. Long to short, trying to buy time with no money for attorney, since I'm trying to pay for attorney to file bankruptcy. Amex suing, answered complaint. Now with Request for Admissions, Interogs, req for docs, etc. I know RCP says "If objection is made, the reasons therefor shall be stated. The answer shall specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. A denial shall fairly meet the substance of the requested admission, and when good faith requires that a party qualify an answer or deny only a part of the matter of which an admission is requested, the party shall specify so much of it as is true and qualify or deny the remainder. An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless the party states that the party has made reasonable inquiry and that the information known or readily obtainable by the party is insufficient to enable the party to admit or deny. A party who considers that a matter of which an admission has been requested presents a genuine issue for trial may not, on that ground alone, object to the request; the party may, subject to the provisions of Rule 37©, deny the matter or set forth reasons why the party cannot admit or deny it."

I need some verbage to respond to my specific situation.

REQUEST FOR ADMISSIONS

1. Admit" that you were extended credit from Plaintiff.

____ Admit

_____ Deny

2. Admit that you received monthly billing statements for the credit card account that is the

subject of this action.

_____ Admit

_____ Deny

3. Admit that you failed to dispute any and all charges set forth on the billing statements.

____ Admit

_____ Deny

4. Admit that you received mail at the address set forth on the billing statements.

_____ Admit

_____ Deny

5. Admit that you signed the card member agreement in order to receive the credit card that

is the subject of this action.

_____ Admit

_____ Deny

6. Admit that you used the credit card account that is the subject of this action for purchases

of goods and/or services.

_____ Admit

_____ Deny

7. Admit that you agreed to make minimum monthly payments to Plaintiff on the account.

_____ Admit

_____ Deny

8. Admit that you made payments on the account in accordance with the card member

agreement.

_____ Admit

_____ Deny

9. Admit that you agreed to pay a finance charge on this account for unpaid balances

pursuant to the card member agreement.

_____ Admit

_____ Deny

10. Admit that you agreed to pay late fees pursuant to the credit card agreement.

_____ Admit

_____ Deny

11. Admit you failed to pay your balance due and owing.

_____ Admit

_____ Deny

12. Admit that you owe the principal balance of$52,954.21, plus interest.

_____ Admit

_____ Deny

13. Admit that you agreed to pay attorney's fees and costs of collection pursuant to the card

member agreement.

_____ Admit

_____ Deny

14. Admit that you transferred outstanding balances for other loans to the credit card account.

_____ Admit

_____ Deny

15. Admit that you were single during the time period the debt alleged in the Complaint was

incurred.

_____ Admit

_____ Deny

Any advice or input would be appreciated.

Ps--will post reqest for documents later, gotta put the kids to bed!

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