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Stuck on what to do next..being sued by Midland in Texas


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History:

5/4/2011 Sued by Midland Funding Assignee of Citibank

5/27/2011 Submitted Original Answer (responses to plaintiff's 1st request for admissions and production)

6/1/2011 Submitted Request for Jury Trial

6/13/2011 Submitted 1st Request for Interrogatories, Production of Documents, and Admissions.

7/12/2011 Received Plaintiff's response to Disclosure, Production and Interogatories.

I want to send a 2nd request for Production of Documents, as everything was denied by Midland. Is it too late? If not, how do I word it? Do I basically resend what I already requested and change it from it from 1st to 2nd request? Also, what do I do about the affidavit that was signed by a Citibank employee concerning the charge off?

I will be posting my docs in the next few posts.

Any help would be appreciated!

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My answer:

MIDLAND FUNDING LLC § IN THE JUSTICE COURT OF

assignee of CITIBANK USA, N.A,

Plaintiff

VS § PRECINCT 1 PLACE1

xxxxxxxx § WILLIAMSON COUNTY, TEXAS

Defendant(s)

RESPONSES TO PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, xxxxxxxx, Defendant in the above styled and numbered cause, and makes and files this, its Original Answer, and respectfully shows:

• All Answers correspond to the numbered paragraphs of the Petition.

• All allegations of the Complaint are denied unless expressly admitted herein.

I. Response: Deny. Responding Party disputes the alleged debt, and lacks sufficient information or knowledge from which to form an opinion as to the truth of the allegation contained therein. Based on Lack of information, Defendant denies the allegations and leaves the Plaintiff to provide proof. Defendant demands strict proof thereof.

II. Response: Deny. This request calls for admission of matter defendant has denied and thus it is improper.

III. Response: Deny. This request calls for admission of matter defendant has denied and thus it is improper.

RESPONSES TO PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS & PRODUCTION

Responding party, xxxxxxx, the Defendant in the above cause, makes the following response to Plaintiff's First Request for Admissions and Production. Defendant responds to the requests in the order in which they appear in Plaintiff's Request.

1. Response: Deny. Defendant has no knowledge or information of this alleged agreement and lacks sufficient information or knowledge from which to form an opinion as to the truth of the allegation contained therein, and leaves the Plaintiff to provide proof. Defendant demands strict proof thereof.

2. Response: Deny. Defendant is at this time without knowledge or information sufficient to form a belief as to the truth of the allegation contained therein, and leaves the Plaintiff to provide proof. Defendant demands strict proof thereof.

3. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

4. Response: Deny. Responding party has no record of receiving any so called “periodic statements” and is at this time without knowledge or information sufficient to form a belief as to the truth of the allegation contained therein, and leaves the Plaintiff to provide proof. Defendant demands strict proof thereof.

5. Response: Deny. Responding Party has no relationship with MIDLAND FUNDING LLC, and has already denied any knowledge of any agreement or account. Thus the request calls for admission of matter defendant has denied and thus it is improper.

6. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

7. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

8. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

9. Response: Deny. Defendant has received no demand for payment from Plaintiff. This request calls for admission of matter defendant has denied and thus it is improper.

10. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

11. Response: Deny. Responding Party has no relationship with MIDLAND FUNDING LLC. This request calls for admission of matter defendant has denied and thus it is improper.

12. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

13. Response: Deny. Responding Party objects to this request because it calls for admission of matter defendant has denied and thus it is improper.

14. Response: Deny. Defendant asserts counterclaims against Plaintiff.

15. Response: Deny. Defendant, not being a lawyer or trained in legal matters, cannot determine whether or not this is true. Calls for guesswork by the Defendant.

16. Response: Deny. Responding Party has no documentation of such “account”, and no evidence has been presented to prove such an “account” exists. No documentation has been presented to show predecessor of “alleged account” conveyed, transferred, assigned rights to the “alleged account”. Defendant leaves the Plaintiff to provide proof. Defendant demands strict proof thereof.

Wherefore, Defendant prays that plaintiff’s cause of action be dismissed with prejudice

at plaintiff’s costs, and that plaintiff be sent forth without remedy, and for such other, and further relief as this court deems proper in all the circumstances.

COUNTERCLAIMS

1. In its attempt to collect an alleged debt from defendant, Plaintiff violated the Fair Debt Collection Practices Act in the following ways:

a. By attempting collection of monies without the expressly authorized agreement allowing Plaintiff to do so.

b. By falsely, deceptively or misleadingly stating or implying that it was the actual creditor, rather than merely an assignee of a debt.

c. By falsely, deceptively or misleadingly implying or suggesting that its agent had actual knowledge of the facts supporting plaintiff’s petition.

d. By falsely, deceptively and misleadingly pleading that the amount of money being sought was “justly due and owing” when such information was outside the knowledge of any agent of plaintiff.

e. By attempting to collect attorney fees that have not, on information and belief, been actually expended, or which have no reasonable basis for being charged.

f. By attaching an affidavit containing false or misleading statements.

g. By attaching an affidavit misleadingly implying that the affiant possessed actual knowledge of the debt involved in this litigation.

h. By attaching an affidavit to the petition served upon the court, but not providing such document to defendant.

i. By filing an unsubstantiated petition in violation of 15 U.S.C. sec. 1692e.

Defendant reserves the right to submit other counterclaims that may become applicable and/or available at a later time, including, but not limited to, violations of the Federal Truth in Lending Act, the Fair Debt Collection Practices Act, and the Fair Credit Reporting Act.

As a direct and proximate result of plaintiff’s violation of the FDCPA, defendant has suffered emotional distress, inconvenience, embarrassment, humiliation and pain and suffering, as well as financial costs incident to defending the suit brought against him.

Wherefore, defendant prays this honorable Court to enter a judgment against plaintiff awarding defendant actual and punitive damages, for consequential and incidental damages, costs of suit, and for such other and further relief as this court deems appropriate in all the circumstances.

Defendant reserves the right to Trial by Jury.

CERTIFICATE OF SERVICE

FURTHERMORE, I do hereby certify that I will mail a true and correct copy of this Original Answer to the Plaintiff on the ¬¬¬______ day of _______________________, 2011.

Signed: ______________________________________

Defendant/Pro Se

Name _____________________________________

Address _____________________________________

City _________ State _____ Zip Code _______

Phone# _____________________________________

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My 1st request for admissions:

MIDLAND FUNDING LLC § IN THE JUSTICE COURT OF

assignee of CITIBANK USA, N.A,

Plaintiff

VS § PRECINCT 1 PLACE1

xxxxxx § WILLIAMSON COUNTY, TEXAS

Defendant(s)

Defendant’s First Request for Admissions Directed to Plaintiff

COMES NOW Defendant, xxxxxxx, and requests that Plaintiff Admit each of the following in accordance with State Law.

That:

1. At the time of filing suit against defendant, plaintiff had no photocopies or originals of documents supporting any claim for money against Defendant.

2. At the time of filing suit against defendant, plaintiff had no independent basis for determining the validity of any debt claimed against defendant other than a computer-tape claiming the amount owed and provided by Original Creditor.

3. That plaintiff does not have the original of any copy of any contract purporting to be the basis of any debt owed by defendant to Original Creditor.

4. That plaintiff did not have any copy or original of any contract purporting to be the basis of any debt owed by defendant to Original Creditor at the time of filing suit against defendant.

Respectfully Submitted,

Signed: ______________________________________

Defendant/Pro Se

Name _____________________________________

Address _____________________________________

City _________ State _____ Zip Code _______

Phone# _____________________________________

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My 1st set of interrogatories:

MIDLAND FUNDING LLC § IN THE JUSTICE COURT OF

assignee of CITIBANK USA, N.A,

Plaintiff

VS § PRECINCT 1 PLACE1

xxxxxxxxx § WILLIAMSON COUNTY, TEXAS

Defendant(s)

DEFENDANTS FIRST SET OF INTERROGATORIES DIRECTED

TO PLAINTIFF

COMES NOW Defendant, xxxxxxxx, and propounds the following interrogatories on Plaintiff, to be answered in accordance with Your State Rules:

DEFINITIONS

“You,” “your” or “yours” means the Plaintiff and any employee, agent, sales representative, manager, officer, owner, independent contractor, assign or other person working for, hired by or acting on behalf of plaintiff.

“Identify” with respect to persons means state the name, address, position, social security number, last known home and business address and last known home and business telephone number for each such person listed.

“Identify” with respect to documents or things means describe the document or thing, state its current whereabouts, and identify each person who has possession, custody or control over each such document.

“The Original Creditor” means the original issuer of the credit that was extended to Defendant, and any employee, agent, sales representative, manager, officer, owner, independent contractor, assign or other person working for, hired by or acting on behalf of the Original Creditor.

“The Account Balance” or “Defendant’s Account” means the debt you allege Defendant owes and upon which you have filed suit to collect.

INTERROGATORIES

1. Please identify each person who either answered, or who was consulted in providing answers to these interrogatories, and state which interrogatory was answered by each such person listed.

ANSWER:

2. Identify each expert witness whom you expect to call at trial, and for each person listed state:

a) His or her occupation;

B) His or her place of employment;

c) His or her qualifications to give an opinion;

d) A list of all cases at which he or she has testified in the past three years;

e) His or her hourly deposition fee; and

f) The general nature of the subject matter on which he or she is expected to testify.

ANSWER:

3. Identify the Original Creditor of Defendant’s Account.

ANSWER:

4. Identify the person or entity from whom you purchased Defendant’s Account.

ANSWER:

5. Identify every document by which Defendant’s Account was transferred to or acquired by you and state whether the transfer was by assignment or some other means.

ANSWER:

6. Identify each of your employees who have attempted to collect the Account Balance from Defendant, and describe what actions were taken by each such employee to collect, or attempt to collect the Account Balance from Defendant.

ANSWER:

7. Identify every individual employed by the Original Creditor who had direct or supervisory authority over Defendant’s Account (or over the department responsible for collecting Defendant’s Account) before it was assigned, transferred and/or sold to you.

ANSWER:

8. State whether you have a copy of any contract that contains Defendant’s signature on it. If your answer is “no,” state whether you have a copy of ANY document that contains Defendant’s signature and, if so, identify each such document.

ANSWER:

9. Identify all documents, including electronic media which you consulted or upon which you relied in generating any documents attached to your petition.

ANSWER:

10. Identify the individual who obtained or compiled the information that was used to generate the documents attached to your petition.

ANSWER:

11. Do you contend that any document attached to your petition is an actual “itemized statement of account?” If your answer is “yes,” state each reason why you contend the document is an “itemized statement of account” and identify the individual(s) who generated the document. For each individual listed, describe the person’s academic background and state the person’s qualifications in knowledge, training or information to produce the “itemized statement of account.”

ANSWER:

12. Did you ever make any agreement to lend money or provide credit to Defendant? If your answer is “yes,” state:

a) The date of the agreement;

B) The place in which the agreement was made;

c) The terms of the agreement;

d) Identify all documents, notes and records which relate any terms of the agreement;

e) Identify all persons present at the time the agreement was made.

ANSWER:

13. Do you contend that you made a demand for payment from Defendant? If your answer is “yes,” give the date on which you made the demand, state the amount you demanded, and identify all documents which reflect the demand.

ANSWER:

14. State the total amount of principal that you contend Defendant borrowed from the Original Creditor, give the date and amount on which each principal sum was borrowed, and identify the goods and/or services that Defendant purchased with the credit that was given.

ANSWER:

15. State the amount of interest that was charged to Defendant pursuant to each principal sum that was borrowed, and describe the manner in which you calculated the interest.

ANSWER:

16. As of the date you made your demand for payment to Defendant, how much of the amount you demanded was principal and how much was interest, and explain the basis of your calculations by making specific reference to the documents on which your calculations are based.

ANSWER:

17. State the amount of each late fee, overlimit fee, membership fee, application fee, or any similar charge that was ever assessed against Defendant with respect to Defendant’s Account.

ANSWER:

18. With respect to Defendant’s Account, do you contend that Defendant was in default on any payments owed to the Original Creditor or anyone else? If your answer is “yes,” give each date on which you contend Defendant was in default and state the amount by which Defendant was in default as of that date.

ANSWER:

19. Describe the exact consideration paid by you to acquire Defendant’s Account. If all or part of the consideration was money, state the exact sum of money that was paid, from whom it was paid, and the date it was paid.

ANSWER:

20. List all information consulted by any agent of plaintiff prior to filing suit to determine the validity of the debt allegedly owed plaintiff by defendant, and identify each agent consulting that information and the date upon which the information was consulted.

ANSWER:

21. State your net worth as of the date of your answers to these interrogatories.

ANSWER:

22. As of the date of your answers to these interrogatories, state the total amount of money you claim Defendant owes you, state the amount of that money that constitutes (1) interest, (2) attorney’s fees, and (3) court costs, list every document that supports your calculation of these figures, identify every document that authorizes you to collect these amounts, give a detailed description of how you calculated these figures, and identify every individual who has personal knowledge of the accuracy of these figures and/or who has personal knowledge that the figures were accurately calculated or determined.

ANSWER:

23. What is total amount of money you have received in payment toward the Account Balance? As to each payment made, specify the date it was made, by whom, and the amount.

ANSWER:

24. What is total amount of money any person has received in payment toward the Account Balance? As to each payment made, specify the date it was made, by whom, by whom received, and the amount.

ANSWER:

25. Identify any declarations, admissions or statements against interest made by Defendant or Defendant’s agents or representatives relating to the subject matter of this litigation, and fully relate all details with regard to each such statement.

ANSWER:

26. Have you obtained any written or oral statements from any persons who have any knowledge of the subject matter of this action? If so, state as to each statement:

a) The name and address of the person making the statement;

B) The date said statements were made;

c) Whether the statements were written, oral or by recording device;

d) The name and address of the person who took the statements;

e) The name and address of the person in possession of the statements;

f) Please attach a copy of each such statement.

ANSWER:

Respectfully Submitted,

Signed: ______________________________________

Defendant/Pro Se

Name _____________________________________

Address _____________________________________

City _________ State _____ Zip Code _______

Phone# _____________________________________

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1st request for production of documents:

MIDLAND FUNDING LLC § IN THE JUSTICE COURT OF

assignee of CITIBANK USA, N.A,

Plaintiff

VS § PRECINCT 1 PLACE1

xxxxxx § WILLIAMSON COUNTY, TEXAS

Defendant(s)

DEFENDANT’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

DIRECTED TO PLAINTIFF

COMES NOW Defendant, xxxxxxx, and requests Plaintiff to produce the following documents, and otherwise respond to these requests for production of documents, within the time provided under the State Rules:

DEFINITIONS

“Document” means, without limitation, all of the following items in Defendant’s possession, custody or control, whether printed, recorded, or reproduced by any other mechanical process or written or produced by hand: agreements, communications, correspondence, telegrams, memoranda, summaries of records of telephone conversations, summaries or records of personal conversations or interviews, video or audio tape recordings, diaries, graphs, reports, notebooks, note charts, plans, drawings, sketches, file vehicles, indexes, logs, summaries or records of meetings or conferences, summaries or reports of investigations and negotiations, opinions or reports of consultants, photographs, brochures, pamphlets, circulars, press releases, drafts, letters, including any marginal comments appearing on any of the documents, checks (cancelled or otherwise), minutes, and any and all other writings. The term “document” also includes all entries made into a computer (please produce a hard copy or disk containing all entries).

“You,” “your” or “yours” means plaintiff, its owners, officers, managers, employees, agents, assigns and sales representatives.

“The Original Creditor” means the original issuer of the credit that was allegedly extended to Defendant, and any employee, agent, sales representative, manager, officer, owner, independent contractor, assign or other person working for, hired by or acting on behalf of the Original Creditor.

“The Account Balance” or “Defendant’s Account” means the debt you allege Defendant owes and upon which you have filed suit to collect.

DOCUMENTS REQUESTED

1. Any and all account cards or ledger sheets showing debits, credits, and/or a running balance, prepared in connection with Defendant’s Account.

2. Any and all written correspondence or notes of oral correspondence between you and Defendant or between you and any third party concerning Defendant’s Account, including copies of any and all notices of default or demands for payment that you or a third party sent to Defendant.

3. Copies of all documents that you received from the Original Creditor in connection with Defendant’s Account.

4. All documents showing the assignment of Defendant’s Account to you or to any intermediate person or entity, beginning with the first assignment by the Original Creditor and ending with the final assignment to you.

5. Any and all documents, not covered by another section of this request, that purport to bear Defendant’s signature and relate to the subject matter of the petition.

6. Any and all documents that you consulted or relied upon in the preparation of the petition or answers to interrogatories.

7. Any document upon which the person who signed the Affidavit attached to the Petition reviewed or relied on prior to signing the Affidavit.

8. Any document upon which the person who generated any documents attached to the petition reviewed or relied on prior to filing your lawsuit.

9. Copies of your federal and state income tax returns for 2008, 2009 and 2010.

10. All documents supporting any calculation of damages against Defendant, including actual damages, attorney’s fees, late fees, overlimit fees, membership fees, application fees, interest calculations and court costs.

11. A copy of any written demands for payment made to Defendant.

12. A copy of any credit applications or credit investigations of Defendant concerning Defendant’s Account.

13. All documents identified in response to Defendant’s interrogatories served herewith and not otherwise produced.

Respectfully Submitted,

Signed: ______________________________________

Defendant/Pro Se

Name _____________________________________

Address _____________________________________

City _________ State _____ Zip Code _______

Phone# _____________________________________

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Thank you 1stStep for quick replies!

In regards to your first reply about filing a motion to preclude the affidavit as being hearsay, is there a good template to follow for that?

Secondly, they did submit a copy of a bill of sale. You will find in plaintiff_written_discovery 21.jpg on my last post. Is that valid?

Lastly, what about submitting a 2nd request for production? Can I just resend what I sent before as they just objected to everything?

Thank you for taking the time to read and reply!

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As far as the bill of sale, it does NOT reference your account... I'd see if you could motion to get that precluded as well...

this is a generic bill of sale that references another Exhibit which is missing. How do you know that you account is included in that exhibit?

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How do this sound?

Cause No. xxxxxxx

MIDLAND FUNDING LLC § IN THE JUSTICE COURT OF

assignee of CITIBANK USA, N.A,

Plaintiff

VS § PRECINCT 1 PLACE1

xxxxxxxx § WILLIAMSON COUNTY, TEXAS

Defendant(s)

DEFENDANT’S FIRST MOTION TO COMPEL PRODUCTION OF DOCUMENTS

DIRECTED TO PLAINTIFF

COMES NOW Defendant, xxxxxxxx, and moves this Court for an Order to compel production by plaintiff in the above-styled matter. In support of this Motion, defendant states as follows.

1. On June 13, 2011, defendant served his First Set of Interrogatories to Plaintiff. A copy of these Interrogatories is attached as Exhibit A.

2. On June 13, 2011, defendant served his First Request for Production to Plaintiff. A copy of this Request is attached as Exhibit B.

3. Plaintiff responded to Defendant’s discovery requests on July 12, 2011. Plaintiff has asserted various privileges or objections to providing the discovery requested (See Exhibit C and D). These objections are improper, and plaintiff should be compelled to produce complete responses without objection within ten (10) days from the date of this Motion, or that Plaintiff’s Petition against Defendant be dismissed without prejudice.

Respectfully submitted,

_______________________

xxxxxxx

CERTIFICATE OF SERVICE

FURTHERMORE, I do hereby certify that I will mail a true and correct copy of this Motion to Compel Production to the Plaintiff on the ¬¬¬______ day of ______________________, 2011.

Signed: ______________________________________

Defendant/Pro Se

Name _____________________________________

Address _____________________________________

City _________ State _____ Zip Code _______

Phone# _____________________________________

Edited by ausag
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Add a prayer for relief...

Wherefore the Defendant prays the Court grant the following:

1. Compel the Plaintiff to respond to the Defendant's First Set of Interrogatories;

2. Compel the Plaintiff to respond to the Defendant's First Request for Production;

3. Dismissal of the suit with prejudice;

4. Any other relief the Court deem just and appropriate

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In your first post, you referenced an affidavit signed by a Citi employee regarding the charge off. Which document was that?

Document "citation_pg7" is a Midland Document. It's not from Citibank. It is not proof Midland purchased your account from Citibank.

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S2tink,

Here is my response to disclosure. It wasn't the best, but probably will suffice. I wasn't quite sure how to word my response to ©. That was mainly my only concern.

xxxxxxx § WILLIAMSON COUNTY, TEXAS

Defendant(s)

RESPONSES TO PLAINTIFF’S REQUEST FOR DISCLOSURE

COMES NOW, xxxxxxxx, Defendant in the above styled and numbered cause, and responds to Plaintiff’s Request for Disclosure, pursuant to Tex. R.Civ.P. 194.2(a)-(f), (i), and (l).

(a) The correct names of the parties to the lawsuit

RESPONSE: Midland Funding LLC assignee of CITIBANK USA, N.A., Plaintiff as named and xxxxxxxx, Defendant as named.

(B) The name, address, and telephone number of any potential parties

RESPONSE: xxxxxxxx

Your Address

(123) 456-7890

© The legal theories and, in general, the factual bases of the responding party’s claims or defenses

RESPONSE: Defendant has denied the allegations raised in Plaintiff’s lawsuit. Defendant disputes the alleged debt, and lacks sufficient information or knowledge from which to form an opinion as to the truth of the allegations. Based on lack of information, Defendant denies the allegations and leaves the Plaintiff to provide proof.

(d) The amount and any method of calculating economic damages

RESPONSE: none at this time

(e) The name address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person’s connection with the case

RESPONSE: none at this time

(f) For any testifying expert:

(1) The expert’s name, address, and telephone number

RESPONSE: none at this time

(2) The subject matter on which the expert will testify

RESPONSE: none at this time

(3) The general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information

RESPONSE: none at this time

(4) If the expert is retained by, employed by, or otherwise subject to the control of the responding party:

(A) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony

RESPONSE: none at this time

(B) the expert’s current resume and bibliography

RESPONSE: none at this time

(i) any witness statements described in Rule 192.3 (h)

RESPONSE: none at this time

(l) the name, address, and telephone number of any person who may be designated as a responsible third party

RESPONSE: none at this time

Defendant reserves the right to amend any answers set forth, at a later time, if needed.

CERTIFICATE OF SERVICE

FURTHERMORE, I do hereby certify that I will mail a true and correct copy of this Response to Plaintiff’s Request for Disclosures to the Plaintiff on the ¬¬¬______ day of ______________________, 2011.

Signed: ______________________________________

Defendant/Pro Se

Name _____________________________________

Address _____________________________________

City _________ State _____ Zip Code _______

Phone# _____________________________________

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Thank you very much, ausag! Im in tx too, fighting a jdb. Your example was very helpful. I am sending my first request for admissions to the plaintiff. Is there anything in addition to the requests outlined in your second request for admissions that I should include in my first? Also, when/how should i send interrogatories or file motions to compel plaintiff to produce docs? I don't think these guys have any paperwork. this acct was written off years ago.

thanks:)

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