my Comprehensive Solutions Case

[Merk]

I was told I should make a thread for my specific case. I need to send discovery requests back. Any suggestions on how to cover my ASSets??? And any suggestions or links to suggestions that are good to send as my own discovery? Here is what they asked me.

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Interrogatories

1. give the names and addresses of persons known to the parties or counsel to be witnesses concerning the facts of this case and indicate whether or not written or recorded statements have been taken from the witness and indicate who has possession of such statements.

Reply:

2. Set forth a list of photographs, plats, sketches, or other prepared documents in possession of the party that relate to the claim or defense in the case.

Requests for production of documents

1. produce all documents which you contend contain information relevant to this civil action

reply

2. Produce all documents mentioned by you in your response to the foregoing interrogatories

reply

3. Produce a copy of all bank account statements concerning any account over which you now or formerly have had withdrawal authority, which statements reflect any credits or debits between (month, 2008 and another month, 2009), inclusive (((I really don't like this one)))

Requests for admissions

1. Admit that you are the defendant in this civil action

2. Admit that you were issued a credit account denominated by number a **************** by Chase Bank USA, NA

3 Admit the plaintiffs exhibit attached hereto is a true and complete copy of the card holder agreement, the terms of which govern the account forming the basis of this civil action.

4. Admit that you agreed to be bound by the aforesaid card holder agreement when the aforesaid account was opened by and/or used by you.

5. Admit that you used the aforesaid credit account.

6. admit that you received the benefit of the use of the aforesaid credit account

7. admit that you knew of the use of the aforesaid credit account in your name at the times of the such use.

8. Admit that you received regular statements from Chase Bank USA, NA reflecting all charges and credits upon the aforesaid account.

9 Admit that you did not dispute charges made or the amount owed on the aforesaid account at the time you received the aforesaid statements

10. Admit that the principal balance on the account is $1000 and some change remains unpaid

11. Admit the interest is accumulating upon the principal balance at the rate of 29.9%

12. admit that the interest is accumulating upon the principal balance from and after the date of (2 months after #3 in requests for docs)

13 admit that you are in default upon the aforesaid account.

14. admit that that the aforesaid agreement allows for the collection of reasonable attorneys fees and costs of court incurred int eh collection of the account.

15 admit thateach of the following documents attached hereto is genuine:

a. statement dated blah

b. statment dated blah blah

c.etc.-> the letter r or s or so.

last letter Chase cardholder agreement.

16. admit that you now or formerly received mail at the following addresses

a, b, c

17 admit that you have no evidences that the plaintiff is not the owner of the account.

18. admit that the plaintiff is the owner of the account

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[BV80]

If you're being sued by a JDB and not the OC, you would send a Request for Production of Documents and ask for a bill of sale, all cc statements showing all charges, payments, interest, and fees beginning with a -0- balance, and all documents which you contend contain information relevant to this civil action.

Here's a link to some interrogatories.

http://www.creditinfocenter.com/forums/there-lawyer-house/307901-iterrogatories-utilize-when-dealing-oc-jdb.html

After they respond with the documents, I'd then send admissions requests based upon the documents they send you and based upon what they didn't send.

[Merk]

Ok will do. Thanks

[nascar]

Merk, Comprehensive Legal Solutions, Inc. is Brock & Scott. Their reputation speaks for itself.

I recognize them from the requests for admission. Their game is they try to elicit certain, specific responses to the requests for admission and if you don't give them, they'll move to have the responses deemed admitted. In other cases, they'll attempt, as a sanction, to have your answer stricken and default awarded.

Use care when answering these requests. To help avoid the aforementioned, you need to admit to those things which are so obvious that no one would believe you can't admit them. Avoid unqualified denials to the extent you can. Some of the requests are intended to lure you into doing that.

You'll want to object to many of the requests, but base your objections on recognized grounds and explain why the request is objectionable for the given reason.

Of course, some of the requests require denials. For instance, request #17, you'll deny.

Request #18, you might consider something like, "Despite having made reasonable inquiry, the information defendant knows or can readily obtain is insufficient to enable him to admit or deny.

Others, you'll want to get a bit creative. Request # 16, for example, "To the extent that defendant may or may not have received mail at the subject addresses does not prove that defendant is indebted to plaintiff, the request is DENIED."

You get the picture, right? You're probably not going to avoid a discovery motion, but if your answers are good enough, you should be able to avoid sanctions.