Help with Response for Admissions, Interrogatories and for production of documents.

[lalasunshine]

Please help. I have this collection company trying to sue me in regards to a Chase credit card that was opened in 2005 with a $500 credit limit. In 2006 I was laid off from my job so I called Chase to activate my Payment Protector coverage. I paid for this coverage additionally to my regular monthly payments. I sent them proof of my unemployment & I was told that it would be activated and I was approved for 6 months & there would be no interest or monthly pymts.I was told by the rep that while the Payment Protection was activated I could still make payments in whatever increments I could afford. So, when my unemployment came through I would send in $10 here $5 there just to get the balance down so that in the event that I did not have a job in 6mths the pymts would be a little more manageable. I noticed that every month I was still getting bills and interest and over the limit fees were popping up. I contacted Chase & I was told not to worry about it and that everything was documented.Long story short at the end of my 6mths I received a statement indicating that I owed over $1,000. I called Chase and they told me that they would correct it. I was 19 & the time and that doesnt excuse my stupidity but I never followed up they didnt contact me anymore and I didnt contact them. That was in 2007. 1/2011 I come home and there is a Summons & Complaint taped to my door (this is all new to me) I was going to throw it away and my friend advised against it. She told me that she did that once & regretted it. She told me to FIGHT THEM. I never knew this collection company had acquired this account until I received the summons & complaint. So I called the court and was informed that I needed to file a motion since I did not agree with the debt. We went to court last month and they wanted to settle for $1600 and $70 monthly payments. I declined their offer. I believe that I owe them $500 only not the $2300 that this collection company is stating! Please help me. I was a 18 yr old college freshman when I got that card. I have not had AND other credit cards since. I dont know much about the court system as I have never been inside of a court before. I was very intimidated going into that court room and felt like I was going to pass out when the judge called my name. I almost stared crying my mom there with me (yeah I'm a big baby) and my dad couldnt make it. Courts freak me out and I just want this to be over I am a 24 yr old nurse and I need your help please,please, please

INT #1

PLEASE IDENTIFY YOURSELF GIVING FULL NAME, ADDRESS AND TELEPHONE NUMBER

REQUEST FOR ADMISSION #1

PLEASE ADMIT THAT YOU RECEIVED THE STATEMENTS FROM CHASE BANK ATTACHED AS EXHIBIT A TO THE SUMMONS AND COMPLAINT AND ALSO TO THIS DOCUMENT AS EXHIBIT 1.

REQUEST FOR ADMISSION #2

PLEASE ADMIT THAT YOU RECEIVED THE STATEMENTS ATTACHED TO PLAINTIFFS COMPLAINT AS EXHIBIT A. (also attached as Exhibit 1 to this discovery request) ON OR ABOUT THE TIME EACH STATEMENT IS DATED.

INT #2

IF YOU ANSWERED IN THE NEGATIVE IN ANSWERING THE REQUEST FOR ADMISSIONS #1 AND #2 PLEASE ADVISE THE FOLLOWING REGARDING THE ACCOUNT IDENTIFIED IN THE STATEMENTS ATTACHED AS EXHIBIT 1:

A. PLEASE IDENTIFY EACH AND EVERY STATEMENT YOU RECEIVED FOR THIS ACCOUNT

B. PLEASE SET FORTH EACH AND EVERY RESIDENCE YOU LIVED AT FOR THE PERIODS OF TIME THESE STATEMENTS ARE DATED.

C. IDENTIFY EACH AND EVERY PAYMENT YOU MADE ON THIS ACCOUNT IDENTIFIED BY THE STATEMENTS ATTACHED AS EXHIBIT 1. FOR THE PERIOD OF TIME IDENTIFIED IN THESE STATEMENTS PLEASE IDENTIFY THE NAME OF EVERY BANKING INSTITUTION YOU DID BUSINESS WITH

D.IDENTIFY EACH AND EVERY DOCUMENT YOU RECEIVED FROM CHASE BANK OR ANY THIRD PARTY REGARDING YOUR ACCOUNT WITH CHASE BANK IDENTIFIED IN THE STATEMENTS AS EXHIBIT 1

RFP#1

PLEASE ATTACH COPIES OF ALL PAYMENT, ARRANGEMENTS, AGREEMENTS, CORRESPONDENCE, TRANSFER DOCUMENTS, SECURITY AGREEMENTS, TRUST DOCUMENTS, STOCK TRANSFERS, CHECKS, RECEIPTS, AND OTHER DOCUMENTS YOU RELY UPON IN YOUR ANSWER TO INT #2

:

INT #3

DID YOU MAKE ANY PAYMENTS ON THIS ACCOUNT? IF SO PLEASE ADVISE EACH AND EVERY PAYMENT INCLUDING THE DATE OF THE PAYMENT, WHERE THE PAYMENT CAME FROM, THE AMOUNT OF EACH PAYMENT, WHO THE PAYMENT WAS MADE OUT TO, WHO WERE THE PAYER AND PAYEE ON THE ACCOUNT AND WHERE THE PAYMENT WAS SENT

INT #4

PLEASE PROVIDE NAME, ADDRESS AND TELEPHONE NUMBER OF EACH BANK, CREDIT UNION OR OTHER FINANCIAL INSTITUTION YOU DID BUSINESS WITH DURING THE TIME THIS ACCOUNT WAS ACTIVE.

RFP#2

PLEASE ATTACH COPIES OF ALL PAYMENTS, FRONT AND BACK, THIS INCLUDES, MONEY ORDERS, CHECKS, RECEIPTS, AND OTHER DOCUMENTS YOU RELY UPON IN YOUR ANSWER TO INT #3

INT #5

DID YOU HAVE ANY CONTACT WITH PLAINTIFF, PLAINTIFF'S ASSIGNOR, CHASE BANK OR ANY THIRD PARTY REGARDING THIS ACCOUNT? IF SO PLEASE ADVISE EACH AND EVERY CONTACT INCLUDING NAME, ADDRESS AND TELEPHONE NUMBER, THE DATE OF EACH CONTACT, WHETHER IT WAS ORAL OR IN WRITING, WHO MADE THE CALL AND WHAT WAS DISCUSSED.

RFP#3

PLEASE ATTACH COPIES OF ALL CORRESPONDENCE, LETTERS, NOTES, ENVELOPES AND ALL OTHER DOCUMENTS YOU RELY UPON IN YOUR ANSWER TO INT #5

INT #6 and RFP #4

A.REFERRING TO THE STATEMENT MARKED EXHIBIT 1; P.1 ATTACHED TO THIS DISCOVERY REQUEST DID YOU OR SOMEONE WITH YOUR AUTHORITY MAKE THE CHARGES OR PAYMENT LISTED ON THE STATEMENT?

B.IF YOUR ANSWER TO INT #6 A IS NOT AN UNQUALIFIED YES PLEASE IDENTIFY WHAT CHARGES OR PAYMENTS YOU DID MAKE AND WHEN YOU BECAME AWARE OF ANY CHARGES YOU DID NOT MAKE.PLEASE ADVISE WHO (INCLUDING CHASE BANK), YOU NOTIFIED OF ANY UNAUTHORIZED CHARGES, WHAT WAS SAID AND WHETHER THE NOTIFICATION WAS IN WRITING. PLEASE ATTACH ALL COPIES OF WRITTEN COMMUNICATION

C.REFERRING TO THE STATEMENT MARKED EXHIBIT 1; P.2 ATTACHED TO THIS DISCOVERY DID YOU OR SOMEONE WITH YOUR AUTHORITY MAKE THE CHARGES OR PAYMENTS LISTED ON THAT STATEMENT?

D.IF YOUR ANSWER TO INT# 6C IS NOT AN UNQUALIFIED YES PLEASE IDENTIFY WHAT CHARGES OR PAYMENTS YOU DID MAKE AND WHEN YOU BECAME AWARE OF ANY CHARGES YOU DID NOT MAKE. PLEASE ADVISE WHO YOU NOTIFIED OF ANY UNAUTHORIZED CHARGES, WHAT WAS SAID AND WHETHER THE NOTIFICATION WAS IN WRITING. PLEASE ATTACH COPIES OF ALL WRITTEN COMMUNICATION

K.REFERRING TO THE STATEMENT MARKED EXHIBIT 1; P. 6 ATTACHED TO THIS DISCOVERY REQUEST DID YOU OR SOMEONE WITH YOUR AUTHORITY MAKE THE CHARGES OR PAYMENTS LISTED ON THAT STATEMENT?

L.IF YOUR ANSWER TO INT# 6K IS NOT AN UNQUALIFIED YES PLEASE IDENTIFY WHAT CHARGES OR PAYMENTS YOU DID MAKE AND WHEN YOU BECAME AWARE OF ANY CHARGES YOU DID NOT MAKE. PLEASE ADVISE WHO YOU NOTIFIED OF ANY UNAUTHORIZED CHARGES, WHAT WAS SAID AND WHETHER THE NOTIFICATION WAS IN WRITING. PLEASE ATTACH COPIES OF ALL WRITTEN COMMUNICATION

1.

REGARDING THIS STATEMENT DID YOU RECEIVE IT ON OR ABOUT FEB. 4, 2007?

2.

DID YOU ACTIVATE THE PAYMENT PROTECTOR BENEFIT AS INDICATED IN THAT STATEMENT? IF SO WHEN DID YOU ACTIVATE THE PAYMENT PROTECTOR BENEFIT AND HOW DID YOU DO IT?

3.

WHAT EVENT CAUSED YOU TO ACTIVATE THE PAYMENT PROTECTOR BENEFIT? PLEASE ATTACH ALL DOCUMENTS WHICH IDENTIFY AND EXPLAIN THE EVENT YOU RELIED UPON

4. DID YOU DISCUSS THIS STATEMENT WITH CHASE BANK? IF SO ADVISE THE DATE OF EACH CONTACT REGARDING THIS STATEMENT, WHO YOU CONTACTED AND WHAT WAS DISCUSSED

REQUEST FOR ADMISSION # 3

PLEASE ADMIT THE FOLLOWING STATEMENT:

A. THAT YOU OWE ON YOUR ACCOUNT TO Chase BANK THE BALANCE DUE ON EXHIBIT 1

INT #7

IF YOUR ANSWERS TO RFA #3 ARE NOT AN UNQUALIFIED YES PLEASE SET FORTH ALL FACTS AND CALCULATIONS YOU RELY UPON IN YOUR ANSWER

RFP#6

PLEASE ATTACH COPIES OF ALL PAYMENTS, CHECKS RECEIPTS, CONTRACTS, PURCHASE ORDERS CORRESPONDENCE, LETTERS, NOTES AND ALL OTHER DOCUMENTS YOU RELY UPON IN YOUR ANSWER TO RFA #3

INT#8

DO YOU ADMIT THAT THERE IS ANY BALANCE DUE PLAINTIFF OR ITS ASSIGNOR CHASE BANK? IF SO PLEASE SET FORTH WHAT YOU BELIEVE IS OWED AND INCLUDE ALL YOUR CALCULATIONS WHICH SUPPORT YOUR ANSWER.

REQUEST FOR ADMISSION #4

PLAINTIFF HAS ATTACHED A COPY OF ITS CHAIN OF TITLE CONSISTING OF 2 ASSIGNMENTS IDENTIFIED AS BILLS OF SALE EXHIBIT 2, PP. 1 AND 2. PLEASE ADMIT THAT YOU HAVE NO INFORMATION, EITHER ORAL OR WRITTEN TO DISPUTE THE CHAIN OF TITLE.

REQUEST FOR ADMISSION #5

PLEASE ADMIT THAT NO ONE ELSE IS REQUESTING PAYMENT FROM YOU ON THIS ACCOUNT AT THE PRESENT TIME

*ANY HELP IS GREATLY APPRECIATED

THANKS!