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donqII

Doc. request problem

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The following is from doc. production request from Plaintiff.

There will be no docs.... they want what defendant is requesting from our side.

But... do we attend this meeting empty handed?...

do we call and say there are no docs?

This is a 3rd party buy out...

____________________________________

PLEASE TAKE NOTICE that pursuant to R. 4:18-1 of the New Jersey Rules of Court, Plaintiff VANZ,LLC - JULY 10 - SERIES 01 demands Defendant,

XXXXXXXXXXXX or its representative produce copies of or an opportunity to inspect and copy the documents specified below within its possession, custody or control. Said production shall take place at the office of XXXXXXXX XXXX &XXXX on November 8, 2010 at 2:00 pm or as mutually agreed upon by the parties or counsel.

The answers below should reflect your knowledge as to dealings with the underlying creditor Chase Bank USA from whom this debt was assigned.

/S/ XXXX X XXXX Esq.

Dated: October 8, 2010

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What documents are they requesting?

1. All correspondence or other written communication between the parties hereto.

2. All documents, memoranda or writing of the kind prepared by or for defendant and sent to plaintiff, in connection with any allegations contained in the pleadings.

3. All documents, memoranda or writing of any kind related in any way to the damages claimed by the plaintiff or the claims of the defendant.

4. All correspondence or other communications passing between the parties or any other person or entity relating to or referring to the activities of plaintiff on behalf of defendant.

5. Any and all checks or other writings relating to payments made by defendant to plaintiff or its predecessors.

6. And individual or summary ledgers regarding the alleged payments of defendant to plaintiff or its predecessors.

7. Any documents in the nature of an accounting with regard to the Damages due plaintiff with regard to the payment and/or credits due to defendant.

8. Any copies of agreements in you possession between the named defendant and plaintiff or any other third-party that you assert concern your liability for the debts which are the subject of this matter.

9. Copies of any other documents or pleadings received from any other party or non-party that is within the defense counsel or third-party plaintiff's possession related to the subject matter of the within litigation.

10. Copies of any reports rendered by experts in regard to the allegations made by the defendant that the services of the plaintiff herein were defective or did not meet the due standard of care.

11. Copies of any and all records or reports of any expert consulted in any manner in regard to the allegations made by

defendant as to the representation by plaintiff herein.

12. Copies of any documents within possession of defendant that are not covered by privilege that may or may not be produced at trial.

13. Copies of any ledgers, checks, drafts or any other documents or instruments within defendant(s) possession that defendant alleges support any claim of payment or entitlement to a credit.

14. Copies of any and all documents with regard to any allegations of damages alleged by Defendant/Counterclaimant in regard to the pending lawsuit.

Failure to comply with this Notice to Produce will result in sanctions provided in Rule 4:23-1.

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I meant to add, if so, they are trying to get you to prove their case for them.

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I meant to add, if so, they are trying to get you to prove their case for them.

No, not Midland... I sent you a pm.

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Interesting update.

Did a little research on the atty. Seems the atty and Plaintiff are one in the same.

The plaintiffs name is a spin off from the atty....

And they appear to be real scum bags.

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