NeedHelpNebraska

Being Sued By Security Credit Services in Nebraska

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How much info should I give them if anything? I feel like I am cutting my self of at the knees if I answer any of these questions...and making the case for the other side.

1. If you deny any of the foregoing requests for admission, please specify in detail the reasons for the denial.

Answer:

2 State your full name, address, telephone number, date of birth, and Social Security number or work permit number.

Answer:

3. State fully, completely, and at length the factual basis for denying that the Plaintiff's assignee performed all of it obligations under the contract.

Answer:

4. State fully, completely and at length the factual basis foe denying that the Defendant defaulted under the agreement by failing to provide the agreement upon payments.

Answer:

5. State fully, completely and at length the factual basis for denying that the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus pre-judgement interest at the statutory rate of 12% per annum, from October 2011 to th date of judgement.

Answer:

6. State fully, completely, and at length the factual basis for denying that demand for the above stated amount was made by the plaintiff to the defendant.

Answer:

7. State fully, completely and at length that the factual basis for denying that monthly statements were mailed to the defendant at the address provided by the defendant.

Answer:

8. State fully, completely and at length the factual basis for denying that the defendant accepted said statements without making objections to.

Answer:

9. State fully, completely and at length any facts upon which the defendant will rely on in defense of this action.

Answer:

10. State the name, occupation, business address and telephone number, residence address and telephone number of witness you expect to call to rely upon in the trial of this action, together with a summary of the matters to be testified about within the knowledge of each witness.

Answer.

11. State the name, occupation, business address and telephone number of each person having knowledge of any facts which are the subject of the above entitled action together with a summary of facts known by each person.

Answer.

12. State the name, occupation, professional credentials, business address and telephone number of each expert you expect to call or rely upon in trial of this action, together with a summary of the matters to be testified about within the knowledge of each such expert.

Answer:

13. State the names and addresses of all persons from whom the defendant, or anyone acting on the defendant's behalf, has obtained statements that in any way relate to the facts or claims which are the subject of the above-entitied action.

Answer:

14. For each statement contained in your Answer to the preceding Interrogatory, state:

a. For each statement was taken:

b. The name and address of the persons who took the statement;

c. the location where the statement was taken;

d. The names and addresses of all persons present at the time the statement was obtained or who otherwise witnessed the taking of the statement;

e. the form of the statement obtained (e.g, written, recorded, etc.);

f. The names and addresses of the custodians on the statement.

Answer:

15. If you have not admitted any one of the Plaintiff's Request for Admissions served upon you this same date, then, with respect to each such Request not fully admitted, state all the facts known to you, directly or indirectly, which you contend to be the basis for the denial or refusal to admit each such Request.

Answer:

16. Are you currently employed? If so:

a. What is the name, address and telephone number of your employer?

b. What is your net ("take-home") pay, per say period?

Answer:

17. Do you own or rent your residence?

a. if you rent, please state:

1. How much is rent?

2. What is the name and address of your landlord?

b. If you own (or are purchasing) your residence, please state:

1. Your monthly payment.

2. the value or your home.

3. how much equity do you have in your home?

4. The name and address of the mortgage holder or deed holder (the entity to whom you send your payments).

Answer:

18. Do you have an active back account? If so, please state:

a. The name and mailing address of the bank or banks.

b. Checking or savings account?

c. The names of all people listed as owners of the bank account.

Answer:

19. What is your marital Status?

Answer?

20. Do you have any minor Children (under 19 Years of age) Living with you?

a. If yes, please state the ages of each child.

Answer

21. Do you won any vehicles? For each vehicle please state:

a. Year, make, and model of vehicle.

b. Monthly payments, if any.

c. Approximate Value of Vehicle.

Answer:

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Last page.

The Plaintiff herein requests the defendants to produce the following documentation and things for inspection and reproduction, within thirty day of the date of service, in accordance with rules 26 and 34 of the Nebraska Discovery for Civil Cases.

1. Document or Documents means writing, drawing, graphs, charts, photographs, correspondence, facsimiles, memorandum, written messages, handwritten or typed notes, evaluations, contracts, diaries, expense records, internal correspondence or memorandum, minutes, resolutions, summaries, statements, drafts of any of the above documents, and any other data compilations from which any information can be obtained or can be translated, if necessary, by the defendant into reasonable usable form.

2. the documents and things should be produced as they are kept in the ordinary course of the defendant's business or within the record keeping system regularly used by the defendant.

3. The party upon whom the request is served shall serve written response with in thirty days after service of the request, unless the request is objected to, in which event the reasons for the objection shall be stated.

Requests:

1. Produce all documents furnished to you by the Plaintiff or the Plaintiff's Assignor.

response:

2. Produce all documents furnished to you by the Plaintiff or to the Plaintiff's Assignor.

Response:

(must be important....its in there twice.)

3. Produce all records showing any payments made on this account,

response:

4. Produce the three most recent tax returns filed by the defendant.

response:

5. Produce the three most recent payroll stubs from the defendant's employment.

response:

(I am self employed...and on paper I do not make a lot of money...how do I show that?)

6. Produce all documents identified in your answers to interrogatories.

response:

7. Produce every document, writing, paper or letter which you intend to utilize as a basis or ground for any defense in this action or which expect to offer into evidence upon the trial on this action.

response.

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A true and correct copy

Object. You have absolutely no way to (or any obligation to) verify and validate the plaintiff's evidence.

currently held by the Plaintiff

Same deal, they are making an unsupported claim of ownership. Never admit or validate something like this.

on or about 9/**/2009

Sorry dude, not copping to this one either. The date is in dispute as it may establish that the SOL has expired.

the account which is the subject of this action was validly sold and assigned

More of the same, prove your own case, you filed it, not me.

That by using the credit card, the Defendant agreed to be bound by the terms of the agreement

Object. This is called "use and acceptance." Plaintiff has not cited any relevant statute proving that this is law in Nebraska.

That the Plaintiff's assignee performed all of its obligations under the Agreement.

plus pre-judgement interest t the statutory rate of 12% per annum

More of the same. How should you know? Calls for a legal conclusion and is therefore improper.

That the Defendant defaulted

"Default is not defined herein, nor were any documents attached that would allow defendant to make an informed decision. Default is either a matter to be determined by the alleged agreement or by the trier of fact.

That there are no facts upon which the Defendant relies as a basis for any defense in this action.

Response

Shove it. You'll find out if you are stupid enough to take me to court. LOL Just deny.

That there are no documents, writings, letter, records or papers of any sort which the Defendant intends to utilize as evidence of or a basis for a defense in this action.

Not at this time but defendant reserves the right to amned per the rules of procedure.

That the material allegations contained in the Plaintiff complaint are true.

You can't be serious. You are a junk debt buyer. Who'd believe anything you say?

This is how you pick them apart. No time to go thru the rest for you, but look for traps. Never validate their evidence. Object to anything that assumes facts not in evidence, like "after you used the card to buy crack, you didn't pay." Where is the evidence about the crack? Object to anything that requires you to make a legal conclusion about statutory stuff, legal terminology, or decisions that the court should be making. Object to anything that requests info about employers, assets, this is all post judgment and improper. All this "state the name of" crap, just say you don't have anybody. The rest becomes moot. Reserve the right to produce documents, you may have an SOL argument and you want that info in. (admitted)

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No court that will allow you to object and not give a specific reason legal reason (vague, work product, etc..) for the objection. If you could do that nobody would ever answer anything.

Your Nebraska rules of procedure will give you the specifics, but if you object, in whole or in part, you have to support your objection with a legal theory.

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"beyond defendant's scope of knowledge" is good for most of these things where they ask you to validate their evidence. Make answers out of what I gave you. Leave out the comedy stuff, of course.

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Do I have to give my financial info....banking, cars, house and so on.....That is more after the judgement right. The more I read the more I understand how this is working. Just want to make sure my answers are correct, and not to allow any evidence the JDB has in to court on my own account.

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I'd object to anything like that as irrelevant. It would be very relevant if you lose and it is part of judgement enforcement, but right now they can shove it.

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Banking info can be relevant to account stated. Coltfan reminded me of this a while back. (he reminds me of a lot of things, some of which I cannot divulge) They may request banking records to see if you made payments on the account which according to them constitues acceptance of the balance, which is a crap argument. You made payments to avoid legal problems while you called them day and night at their call center in Bangladesh where some idiot gave you the run around. Of course you can say you don't have them, paper is a fire hazard, then if they are committed they will have to subpoena the records from the bank if they know who the bank is.

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They have included copies of statements from the credit card that show payments, but it does not show who made them. It just says automatic payment, thank you. Clearly I am headed toward the proof of standing....correct.

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They have included copies of statements from the credit card that show payments, but it does not show who made them. It just says automatic payment, thank you. Clearly I am headed toward the proof of standing....correct.

Well standing is a great, if not the greatest argument, but it has nothing to do with credit card statements not showing who made a payment or showing automatic payments or anything.

Read this.

http://www.creditinfocenter.com/forums/there-lawyer-house/312714-standing-when-dealing-jdb.html

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Banking info can be relevant to account stated. Coltfan reminded me of this a while back.

Thanks for the kick in the nuts, but yes, if they are trying to show payments made on an account from a specific bank account over a long period of time you would probably be required to disclose.

However, while it would defiantly make a prima facie argument you made those payments, they would still not prove who made them, but they would be in a lot better position to question you about it.

The rest of the stuff, like cars, is only if you lose. Unless they are alleging you bought a car with a credit card.

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I am not real sure how to say my objections, I feel I am repeating my self alot here. Please look this over and offer any advice.

Thanks.

1. That the following documents are attached hereto:

Exhibit a: A true and correct copy of Customer Agreement

Exhibit B: A true and Correct copy of Billing Statements March 09 to January

Exhibit C: A true and correct copy of Bill of Sale

Exhibit D: A true and correct copy of Application sighed by you.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s evidence.

2. That the defendant entered into an agreement that is currently held by the Plaintiff by applying for and obtaining a Credit card bearing account number xxxx-xxxx-xxxx-xxxx(exhibit A)

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s evidence, as the Plaintiff is making an unsupported claim of ownership.

3. That the defendant used said credit card, making periodic payments on the account until on or about 9/**/2009.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s evidence, as the Plaintiff’s date is in dispute as it may establish that the Statue of Limitations has expired.

4. That by using the credit card, the Defendant agreed to be bound by the terms of the agreement.

Response: Objection, the Plaintiff has not cited any relevant statute proving that this is law in Nebraska

5. That the account which is the subject of this action was validly sold and assigned to the Plaintiff.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim, as the Plaintiff is making an unsupported claim of ownership.

6. That the Plaintiff's assignee performed all of its obligations under the Agreement.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is calling for a legal conclusion, and therefore is improper.

7. That the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus prejudgement interest at the statutory rate of 12% per annum, from Oct 2011 to date judgement is entered herein.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is calling for a legal conclusion, and therefore is improper.

8. That demand for the above stated amounts has been make by the Plaintiff to the Defendant.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is making an unsupported claim.

9. That the monthly statements were mailed to the Defendant at the address provided by the Defendant.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim.

10. That the Defendant accepted said statements without making objection thereto.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim.

11. That the Defendant defaulted by failing to make payments in the amount set forth on said statements.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Default is not defined herein, not were any documents attached that would allow the Defendant to make an informed decision. Default is either a matter to be determined by the alleged agreement or by the trier of fact.

12. That, after due demand, the Defendant remains indebted to the Plaintiff in the amount of $xx,xxx plus pre-judgment interest t the statutory rate of 12% per annum, from Oct 2011 to the date of judgment in entered herein.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is calling for a legal conclusion, and therefore is improper.

13. That there are no facts upon which the Defendant relies as a basis for any defense in this action.

Response: Deny

14. That there are no documents, writings, letter, records or papers of any sort which the Defendant intends to utilize as evidence of or a basis for a defense in this action.

Response: Not at this time, but the Defendant reserves the right to amend per the Rules of Procedure.

15. That the material allegations contained in the Plaintiff complaint are true.

Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim.

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13 is the best response to the whole set.

Most of the objections are not legal objections. You object and then you lay out the perfect reason on why you should have just objected. Also, I read the rules of procedure. I'm not sure you can get by without admitting or denying based on the strategy you are using (most rules won't let you not admit or deny using the I don't have enough info strategy and you might be setting yourself up to have the admissions deemed admitted, you'll have to check the rules).

Then 1/2 the time you catch them when they are trying to assume facts and then the other 1/2 you never challenge their assumptions.

Can't go through them all but for one example.

# 2 while I would word the objection a lot different you are on the right path about the claim of ownership.

# 6 you then let them slip by the fact they are the assignee. You correctly call them out on the fact it's a legal conclusion but the real issue is they have not proven they are the assignee but are calling themselves, and stating it as a fact that has not be established, the assignee.

Then # 4, they way you word that is that you are admitting if they have Nebraska law backing them up. I mean they are making the HUGE assumption you used the card and your response is you want relevant Nebraska law that states use of the card establishes an agreement (which it does by the way)?

I'd do a 90% do over. You're on the right path with your line of thinking but you're all over the place and trying to get way too fancy with your objections.

The more you write, the more opportunity you will say something or contridict yourself that will hurt your case. The good ole one word deny or admit are the way to go.

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Admissions:

1. That the following documents are attached hereto:

Exhibit a: A true and correct copy of Customer Agreement

Exhibit B: A true and Correct copy of Billing Statements March 09 to January

Exhibit C: A true and correct copy of Bill of Sale

Exhibit D: A true and correct copy of Application signed by you.

Response: Denied

2. That the defendant entered into an agreement that is currently held by the Plaintiff by applying for and obtaining a Credit card bearing account number xxxx-xxxx-xxxx-xxxx(exhibit A)

Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation.

3. That the defendant used said credit card, making periodic payments on the account until on or about 9/**/2009.

Response: Denied

4. That by using the credit card, the Defendant agreed to be bound by the terms of the agreement.

Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation.

5. That the account which is the subject of this action was validly sold and assigned to the Plaintiff.

Response: OBJECTION The request is beyond the scope of the defendant's knowledge and calls for a legal conclusion. Assignment constitutes standing to sue, which is the burden of the plaintiff to prove, not defendant.

6. That the Plaintiff's assignee performed all of its obligations under the Agreement.

Response: Denied

7. That the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus prejudgment interest at the statutory rate of 12% per annum, from Oct 2011 to date judgment is entered herein.

Response: Denied.

8. That demand for the above stated amounts has been made by the Plaintiff to the Defendant.

Response: Denied

9. That the monthly statements were mailed to the Defendant at the address provided by the Defendant.

Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation.

10. That the Defendant accepted said statements without making objection thereto.

Response: Denied

11. That the Defendant defaulted by failing to make payments in the amount set forth on said statements.

Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation.

12. That, after due demand, the Defendant remains indebted to the Plaintiff in the amount of $xx,xxx plus pre-judgment interest t the statutory rate of 12% per annum, from Oct 2011 to the date of judgment in entered herein.

Response: Denied.

13. That there are no facts upon which the Defendant relies as a basis for any defense in this action.

Response: Denied

14. That there are no documents, writings, letter, records or papers of any sort which the Defendant intends to utilize as evidence of or a basis for a defense in this action.

Response: Not at this time, but the Defendant reserves the right to amend per the Rules of Procedure.

15. That the material allegations contained in the Plaintiff complaint are true.

Response: Denied

Edited by NeedHelpNebraska

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Interrogatories:

1. If you deny any of the foregoing requests for admission, please specify in detail the reasons for the denial.

Answer: Defendant is not legally liable to the Plaintiff as to each and every allegation.

2. State your full name, address, telephone number, date of birth, and Social Security number or work permit number.

Answer: This information is, upon information and belief, already in Plaintiff's possession. The term 'work permit number" is unknown to Defendant.

3. State fully, completely, and at length the factual basis for denying that the Plaintiff's assignee performed all of it obligations under the contract.

Answer: OBJECTION Beyond defendant's scope of knowledge. Ownership of the account has not been established as fact. Defendant has no clue as to the business practices of junk debt buyers

4. State fully, completely and at length the factual basis foe denying that the Defendant defaulted under the agreement by failing to provide the agreement upon payments.

Answer: Objection, The request is beyond the scope of the Defendant’s knowledge and calls for legal conclusion. Defendant has denied entering into an agreement with Plaintiff.

5. State fully, completely and at length the factual basis for denying that the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus pre-judgment interest at the statutory rate of 12% per annum, from October 2011 to the date of judgment.

Answer: Objection, no complete record of the alleged debt has been included, therefore defendant cannot make an informed response.

6. State fully, completely, and at length the factual basis for denying that demand for the above stated amount was made by the plaintiff to the defendant.

Answer: Denied, as the burden of proof is on the Plaintiff to prove that the Defendant owes said amount.

7. State fully, completely and at length that the factual basis for denying that monthly statements were mailed to the defendant at the address provided by the defendant.

Answer: Objection, Calls for a conclusion related to the mailing practices of a third party, which is beyond the scope of knowledge of Defendant

8. State fully, completely and at length the factual basis for denying that the defendant accepted said statements without making objections to.

Answer: Objection, no proof of delivery of the alleged statements has been included, therefore Defendant can not make an informed response.

9. State fully, completely and at length any facts upon which the defendant will rely on in defense of this action.

Answer: Defendant is not legally liable to the Plaintiff.

10. State the name, occupation, business address and telephone number, residence address and telephone number of witness you expect to call to rely upon in the trial of this action, together with a summary of the matters to be testified about within the knowledge of each witness.

Answer: Defendant has no witnesses at this time.

11. State the name, occupation, business address and telephone number of each person having knowledge of any facts which are the subject of the above entitled action together with a summary of facts known by each person.

Answer: Defendant has no said persons at this time.

12. State the name, occupation, professional credentials, business address and telephone number of each expert you expect to call or rely upon in trial of this action, together with a summary of the matters to be testified about within the knowledge of each such expert.

Answer: Defendant has no said experts at this time.

13. State the names and addresses of all persons from whom the defendant, or anyone acting on the defendant's behalf, has obtained statements that in any way relate to the facts or claims which are the subject of the above-entitled action.

Answer: Objection, no proof of delivery the alleged statements has been included, therefore Defendant cannot make an informed response.

14. For each statement contained in your Answer to the preceding Interrogatory, state:

a. For each statement was taken:

b. The name and address of the persons who took the statement;

c. the location where the statement was taken;

d. The names and addresses of all persons present at the time the statement was obtained or who otherwise witnessed the taking of the statement;

e. the form of the statement obtained (e.g, written, recorded, etc.);

f. The names and addresses of the custodians on the statement.

Answer: Do I put my name and address

15. If you have not admitted any one of the Plaintiff's Request for Admissions served upon you this same date, then, with respect to each such Request not fully admitted, state all the facts known to you, directly or indirectly, which you contend to be the basis for the denial or refusal to admit each such Request.

Answer: Defendant is not legally liable to the Plaintiff as to each and every allegation.

16. Are you currently employed? If so:

a. What is the name, address and telephone number of your employer?

b. What is your net ("take-home") pay, per say period?

Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.

17. Do you own or rent your residence?

a. if you rent, please state:

1. How much is rent?

2. What is the name and address of your landlord?

b. If you own (or are purchasing) your residence, please state:

1. Your monthly payment.

2. the value or your home.

3. how much equity do you have in your home?

4. The name and address of the mortgage holder or deed holder (the entity to whom you send your payments).

Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.

18. Do you have an active back account? If so, please state:

a. The name and mailing address of the bank or banks.

b. Checking or savings account?

c. The names of all people listed as owners of the bank account.

Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.

19. What is your marital Status?

Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.

20. Do you have any minor Children (under 19 Years of age) Living with you?

a. If yes, please state the ages of each child.

Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.

21. Do you won any vehicles? For each vehicle please state:

a. Year, make, and model of vehicle.

b. Monthly payments, if any.

c. Approximate Value of Vehicle.

Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.

Edited by NeedHelpNebraska

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Again, please look this over, if I am getting to bold with my objections, please someone reel me in. I left 6 blank...I have no documents...is it ok to put that?

Thanks, in advance.

Production of Documents:

1. Produce all documents furnished to you by the Plaintiff or the Plaintiff's Assignor.

Response: Defendant has no such documents either because they have been lost, destroyed, were never created, or in the Defendant’s possession in the first place.

2. Produce all documents furnished to you by the Plaintiff or to the Plaintiff's Assignor.

Response: Defendant has no such documents either because they have been lost, destroyed, were never created, or in the Defendant’s possession in the first place.

3. Produce all records showing any payments made on this account,

Response: Defendant has no such documents either because they have been lost, destroyed, were never created, or in the Defendant’s possession in the first place.

4. Produce the three most recent tax returns filed by the defendant.

Response: Objection. Plaintiff requests personal and private information that is irrelevant and unlikely to lead to admissible evidence.

5. Produce the three most recent payroll stubs from the defendant's employment.

Response: Objection. Plaintiff requests personal and private information that is irrelevant and unlikely to lead to admissible evidence.

6. Produce all documents identified in your answers to interrogatories.

Response: None at this time, but the Defendant reserves the right to amend per the Rules of Procedure.

7. Produce every document, writing, paper or letter which you intend to utilize as a basis or ground for any defense in this action or which expect to offer into evidence upon the trial on this action.

Response: The Defendant demands strict proof, and the burden of proof is on the Plaintiff to prove standing to sue.

Edited by NeedHelpNebraska

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Responding party lacks sufficient information and belief in order to admit or deny this request and on that basis denies same

I always hated this answer, still do. It's what I call the amnesia defense. People overuse it.

State your full name, address, telephone number, date of birth, and Social Security number or work permit number.

This information is, upon information and belief, already in Plaintiff's possession. The term 'work permit number" is unknown to defendnat.

The interrogatory is onerous

define onerous without looking it up.

When you make denials, this is what happens. It's like throwing a big bluff at Doyle Brunson.....what do you do when he smiles and calls you? You can't make denials unless you can explain the reason. "I don't have any information" won't fly. You apparently had enough to make a denial, didn't you? I gave you the reason for 4 and 5, you need to use it. Look at 6 again, you admitted to this. Anything related to employment is post judgment and improper. Go through these again and come up with some valid arguments. Think like them.....anything they want is bad for you.

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I can't go through them all but anytime they say Plaintiff's assignee, I'd be objecting as that assumes facts not in evidence that the Plaintiff is in fact the assignee. That is a legal conclusion, facts not in evidence, and truly beyond the scope of knowledge the Defendant could have. It's impossible to know if they are the assignee because the Defendant was not privy or a party to the alleged transcation assigning the alleged account. They saying they are the assignee is not proof.

Also, the admissions look fine but no need to do all to the best of my knowledge (also talk in third person, not first).

The Defendant has no documents (or whatever) but will properly comply with Nebraska Rules of Civil Procedure (your rules probably say you have to supplement your request if your answer would change). It's not fatal, but still way too much unnecessary commentary going on, in my opinion.

"9. State fully, completely and at length any facts upon which the defendant will rely on in defense of this action."

Answer: The burden of proof is on the plaintiff to prove that the Defendant owes the demands brought forth by the Plaintiff. Not a horrible answer and you're right, It will work for sure, but I'd go with-

Defendant is not legally liable to the Plaintiff. You just covered it all right there. Never said you did not owe anything never denied their evidence, never flipped the burden to yourself and have basically said put up or shut up. You've said the same thing but "legally liable" pretty much says for everything I'm sitting back and making you meet your burden.

3. State fully, completely, and at length the factual basis for denying that the Plaintiff's assignee performed all of it obligations under the contract.

Answer: Objection, beyond Defendant's scope of knowledge.

True, but why the objection?

15. If you have not admitted any one of the Plaintiff's Request for Admissions served upon you this same date, then, with respect to each such Request not fully admitted, state all the facts known to you, directly or indirectly, which you contend to be the basis for the denial or refusal to admit each such Request.

Defendant is not legally liable to the Plaintiff as to each and every allegation.

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I just finished updating my discovery answers. If there are any issues that some one sees, please let me know asap, as I am submitting them this afternoon. Thanks for all the help, and I am starting on my return discovery to the plaintiff.

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