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Help with Midland Funding Interrogatories?


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I have spent several hours doing research and understand that I will answer the reasonable questions within the interrogatories and will object to the others. There are a few, however, that I am not sure how to answer or which argument to support the objection is appropriate. Any help you can offer is much appreciated!

Interrogatories

Please answer the following interrogatories within thirty days after service of said Interrogatories:

1. State your personal identifying information, including your full name, social security number, date of birth, any names used in the last seven years, residential addresses for the past seven years, residential phone number, work address, and work phone number.

2. State the name and address of each person answering, or who assisted in the answering of these Discovery requests or who has otherwise provided Defendant assistance in this case, including the nature of said assistance. (Would I reply n/a? Does help here qualify?)

3. Please state all books, records, papers, and other documents you searched and/or reviewed in conjunction with answering these Discovery requests. (Wondering again if this site would need to be disclosed, or which objection would be relevant here.)

4. State whether you have ever been convicted of any felony. If you have been, state the crime or crimes and the applicable date, location and court for each.

5. For each and every residence that you have maintained for the past ten (10) years provide the mailing address and the time periods when you resided at the residence (I don't remember any of my addresses before 6 years ago.)

6. State the basis for any defenses you have raised against he Plaintiff's claims in this Action. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

7. State the name, address, and telephone number of any witness who has information regarding the claims or defenses raised in this Action. For each witness identified, provide a reasonably detailed statement of their involvement in or knowledge of matters relevant to this Action.

8. State the name, address, and telephone number of any witness (including experts) whom you intend to call at a trial of this Action. For each witness identified, provide a reasonably detailed statement of their anticipated testimony relevant to this Action.

9. State the name, address and telephone number of any person who has provided advice or who has helped you in any way to defend this Action. For each person identified, provide a reasonably detailed statement of their involvement in this Action. (Does this fall under the privilege umbrella?)

10. If you dispute the Account Balance as stated by the Plaintiff, state the amount you believe you owe, and explain how you calculated the amount, identifying specifically any documents that support your calculation.

11. State the name, address and telephone number of any person who used or made any charges to the Account in addition to you.

12. For each payment you made on the Account, provide the date of the payment, the amount of the payment, the manner of payment (i.e., check, cash), the name of the party paid and the address where you sent payment. (Information they should already have?)

13. State the name of every financial institution (bank, credit union, etc.) that has, or has had within the past 10 years, an accoutn (savings, checking, etc.) on which you are a signer, co-signer, owner, user, or otherwise authorized to access.

14. For each fact from the Requests for Admission below that you did not admit without any qualification or objection, state the basis for your objection. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

Request for Production of Documents

Instructions

A. None of the requests below limits any of the other requests. Each request must be construed broadly so as not to exclude any material that is relevant or "appears reasonably calculated to lead to the discovery of other admissible evidence." Utah R. Civ. P. 26(B)(1).

B. Each request must be answered independently of the other requests.

C. You have a duty to produce all documents indicated in the categories below: "[R]equests for production should not be read or interpreted in an artificially restrictive or hypertechnical manner to avoid disclosure of information failry covered by the discovery request, and to do so is subject to appropriate sanctions." Fed. R. Civ. P. 37(a) advisory committee's note (1993).

Production Requests

Please produce the following documents by providing legible photocopies of the originals to Plaintiff's attorneys within thirty days after service of the requests upon you.

1. Any documents that relate or refer to the Plaintiff's claims, your defenses, and/or your counterclaims in this Action.

2. Any agreements, applications, statements, receipts, proofs of payment or other documents related to the Account.

3. Any correspondence with CAPITAL ONE BANK (USA), N.A. or the Plaintiff regarding the Account or this Action.

4. Cancelled checks or check book stubs which indicate any payment on the Account in question.

5. Any correspondence with anyone related to this account, including without limitation, any witnesses, processionals, and experts (whether they have been retained to testify or not).

6. Any documents identified in your answers to the Interrogatories above.

7. Any documents you may present as evidence or exhibits in a trial of this Action.

8. Any reports or exhibits prepared by any expert or lay witnesses pertaining to this Action.

9. Any documents relating to any witness you intend to call at trial.

REQUESTS FOR ADMISSION

Instructions

A. The following requests for admission will be deemed admitted ifnot responded to within 30 days after service.

B. The purpose of requests for admission is "to establish admission of facts about which there is no real dispute" for the purpose of "expediting and streamlining litigation." 7 Moore's Federal Practice, 36.02[1] (Matthew Bender 3d ed.). You have an obligation to cooperate in this process.

C. Refusing to answer or simply denying a request for admissionon grounds that it deals with a question of law is improper: you may be asked to admid the "truth of any matters within the scope of Rule 26(B) set forth in the request that relate to statements or opinions of fact or of the application of law to fact." Utah R. Civ. P. 36(a)(1).

D. "A denial shall fairly meet the substance of the requested admission, and when good faith requires that [you] qualify [your] answer or deny only a part of the matter of which an admission is requested, [you] shall specify so much of it as is true and qualify or deny the remainder." Utah R. Civ. P. 36(a)(2).

E. You may not give lack of information or knowledge as a reason for failing to respond unless you have "made reasonable inquiry and that the information known or readily obtainable by him is insufficient to enable him to admit or deny." Utah R. Civ. P. 36(a)(2).

Requests for Admission

Please admit the following facts:

1. Admit you entered into a contract with CAPITAL ONE BANK (USA), N.A. creating a credit account.

2. Admit you agreed to pay for the credit balance on the Acount.

3. Admit you used, or authorized the use of, the Account to obtain goods, services, or money.

4. Admit you received periodic written statements which reflected each transaction, including purchases and/or cash advances, finance charges, late charges, and payments made on the Account which is the subject of this law suit.

5. Admit you did not dispute, in writing, any charges made on said Account or the application of any of the payments to said account within sixty days.

6. Admit you failed to make payments pursuant to the terms of the credit agreement.

7. Admit you are indebted to Plaintiff as the assignee of CAPITAL ONE BANK (USA), N.A. for the full Account Balance stated above.

8. Admit you agreed to pay interest on the Account Balance at the rate of 10.00% per annum, plus any additional court costs, both pre and post judgment, and attorney fees incurred to enforce the agreement.

9. Admit you have not evidence to disprove or defend against Plaintiff's claims in the Action.

10. Admit you have no evidence indicating that the account in question was not assigned to Plaintiff.

How do I answer when I don't have information that they are requesting? Do I also object? How do I figure out which reasons for objecting are most appropriate for the questions?

I am also wondering as to how to respond to the questions that don't have an answer (particularly the ones that ask for contact info or correspondence with others--there are none in this case). When answering, do I just say "N/A"? Do I need to further clarify or object?

Do I need to add an oath/declaration at the end with my signature? Or can I just submit it as I did my answer to the summons?

Do I need to wait to hear from them to mail in my Request for Discovery or can I do it when I send this in (different envelopes)?

Thank you for any light you can shed on my situation!!

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Check your rules of procedure on when you can serve them discovery. However, generally speaking, you can hit them with discovery as soon as your served the lawsuit. I am 99.9% sure now is the time to serve discovery on them, not wait until they reply.

If you don't have something you don't really have to object. You just state, usually after reasonable efforts were taken, you don't have whatever or never had. You can also state you will supplement your response. For example, your witness list.

Midland is a junk debt buyer. I would research standing. It is a powerful weapon against JDB.

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Yes, I agree.

I am particularly hung up on:

6. State the basis for any defenses you have raised against he Plaintiff's claims in this Action. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

Is that work product? I raised a lot of affirmative defenses in my summons answer (I have read many of your posts and know you disagree with that tactic, ColtFan1972, but it's already been submitted). Do I need to answer/defend them all here and now?

14. For each fact from the Requests for Admission below that you did not admit without any qualification or objection, state the basis for your objection. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

Isn't that supposed to be addressed in that section? This is #14 in the interrogatories. Not sure how to answer that.

As far as the Production Requests, how do I object to turning in what they are asking for? They are requesting documents that would have me make their case for them. I mightily object to that, just don't know which argument to support it would be (I would suspect the same argument for objecting to them would apply to all or most of them).

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I am particularly hung up on:

6. State the basis for any defenses you have raised against he Plaintiff's claims in this Action. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

Do some research on "premature contention interrogatory."

For future reference, this is an example of a "compound interrogatory." While not necessarily objectionable for that reason alone (courts will generally not require the requesting party to reissue separate questions), be aware that in the context of the maximum amount of interrogatories allowed, I believe this one would count as three.

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I am particularly hung up on:

14. For each fact from the Requests for Admission below that you did not admit without any qualification or objection, state the basis for your objection. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

Isn't that supposed to be addressed in that section? This is #14 in the interrogatories. Not sure how to answer that.

This interrogatory is improper and should be objected to. When responding to a request for admissions, you are allowed to admit, deny, or explain why you can neither admit or deny. Nothing further is required.

An interrogatory that attempts to force you to elaborate on your denial of a request for admissions is beyond the scope of discovery allowed in Rule 33 (federal rules, your state may number differently).

Moreover, say, for example that you were given 20 requests for admission and you denied them all. This interrogatory, taken literally, is asking you 20 separate questions. Why did you deny #1, Why did you deny #2, etc. Think about what I posted earlier about "compound interrogatories" and you can see where this is going.

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I am particularly hung up on:

As far as the Production Requests, how do I object to turning in what they are asking for? They are requesting documents that would have me make their case for them. I mightily object to that, just don't know which argument to support it would be (I would suspect the same argument for objecting to them would apply to all or most of them).

OBJECTION: Plaintiff is requesting documents that would prove his case.

Pretty stupid, isn't it. First, this tells me that you owe the money and know you do, but that is neither here nor there.

If you have documents responsive the request, you have a duty to disclose them. On the other hand, you can't produce what you don't have. If you don't have the requested documents, answer by stating you have no documents responsive to the reqeust. That choice is yours.

On the other hand, are the requests for production specific enough to allow you to identify a certain document or set of documents?

Keep in mind that requests for "any and all" documents in your possession that relate to the case; "any and all" documents that tend to support your contentions or defenses, etc. are objectionable as vague and overly broad.

As a "litmus" test of sorts, imagine all the documents of any type whatsoever you have in your possession are spread out on a big table. When you read the request for production, could you go right to the document that is being requested, or would you have to fish through all of them trying to decide which ones meet the substance of the request.

If you can't recognize and go right to the document being requested, the request may be vague, overly broad or unduly burdensome and thus objectionable.

Keep in mind however, that if you claim to have documents that support your defense, you're expected to cough them up if you're asked for them.

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Nascar has given you some good info. However now is the time to strike with a motion to dismiss. Midland is not registered as a Collection Agency under the Utah Collection Agencies Act Title 12 Chapter 1. They can not maintain suit per this act. I have not done a case law search at all as of yet since I am usually hauling JDBs into court before they get the chance to even think about court action.

The CAA uses the definition of a collection agency from the FDCPA, so Midland is a Collector. There is no private right of action, but since it only permits suit if they are registered and bonded, dismissal is the only appropriate action for the court to take.

http://www.creditinfocenter.com/forums/newreply.php?do=newreply&noquote=1&p=1134663

Although there is no private right of action, any violation of law is a violation of the FDCPA as an unfair or deceptive trade practice as well as a violation of the Utah Consumer Sales Practices Act. Read Counter Claim. USSPA is Title 13 Chapter 11 and does have a private right of action and a violation is a min of $2000 (not an up to, but a hard $2000). Interestingly if you were to win, the act also requires you to mail a copy of the court decision to the Division of Consumer Protection for further enforcement action.

Utah Code -- Title 13 -- Chapter 11 -- Utah Consumer Sales Practices Act

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I don't like giving these guys anything, make them work for it and make them bleed money to pursue this. Perhaps some of these would work.

1. State your personal identifying information, including your full name, social security number, date of birth, any names used in the last seven years, residential addresses for the past seven years, residential phone number, work address, and work phone number.

OBJECTION Irrelevant, immaterial, and not likely to lead to the discovery of admissible evidence. Certainly plaintiff has defendant's name and address. Nothing else is needed.

2. State the name and address of each person answering, or who assisted in the answering of these Discovery requests or who has otherwise provided Defendant assistance in this case, including the nature of said assistance.

Defendant responded to the requests personally based upon his / her own knowledge. The remainder of the request is irrelevant.

3. Please state all books, records, papers, and other documents you searched and/or reviewed in conjunction with answering these Discovery requests. (Wondering again if this site would need to be disclosed, or which objection would be relevant here.)

OBJECTION Irrelevant, immaterial, and not likely to lead to the discovery of admissible evidence

4. State whether you have ever been convicted of any felony. If you have been, state the crime or crimes and the applicable date, location and court for each.

OBJECTION Irrelevant, immaterial, and not likely to lead to the discovery of admissible evidence. This is a civil action, not a criminal case.

5. For each and every residence that you have maintained for the past ten (10) years provide the mailing address and the time periods when you resided at the residence (I don't remember any of my addresses before 6 years ago.)

Give them a couple where you never received statements in addition to the normal ones

6. State the basis for any defenses you have raised against the Plaintiff's claims in this Action. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

OBJECTION Calls for impressions of counsel and is violative of the work product doctrine. Witnesses’ information will be provided if and when needed.

7. State the name, address, and telephone number of any witness who has information regarding the claims or defenses raised in this Action. For each witness identified, provide a reasonably detailed statement of their involvement in or knowledge of matters relevant to this Action.

Witnesses’ information will be provided if and when needed. At this time defendant has no plans to call witnesses.

8. State the name, address, and telephone number of any witness (including experts) whom you intend to call at a trial of this Action. For each witness identified, provide a reasonably detailed statement of their anticipated testimony relevant to this Action.

Asked and answered

9. State the name, address and telephone number of any person who has provided advice or who has helped you in any way to defend this Action. For each person identified, provide a reasonably detailed statement of their involvement in this Action.

Defendant has relied upon his / her own knowledge. The remainder is irrelevant to the instant action.

10. If you dispute the Account Balance as stated by the Plaintiff, state the amount you believe you owe, and explain how you calculated the amount, identifying specifically any documents that support your calculation.

Defendant avers he / she owes not one penny to the plaintiff.

11. State the name, address and telephone number of any person who used or made any charges to the Account in addition to you.

OBJECTION Argumentative, assumes defendant made charges, which is assumptive

12. For each payment you made on the Account, provide the date of the payment, the amount of the payment, the manner of payment (i.e., check, cash), the name of the party paid and the address where you sent payment. (Information they should already have?)

OBJECTION The information sought is equally available to plaintiff through its business records

13. State the name of every financial institution (bank, credit union, etc.) that has, or has had within the past 10 years, an account (savings, checking, etc.) on which you are a signer, co-signer, owner, user, or otherwise authorized to access.

OBJECTION Irrelevant, immaterial, and not likely to lead to the discovery of admissible evidence.

14. For each fact from the Requests for Admission below that you did not admit without any qualification or objection, state the basis for your objection. Provide the specific facts or laws that support your position; identify by name, address, and telephone number any witnesses who may have information supporting your position; and identify any documents that may support your position.

OBJECTION Compounded and confusing. Objections will be set forth in the Admissions with reasons therefore.

Edited by legaleagle
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Request for Production of Documents

Instructions

A. None of the requests below limits any of the other requests. Each request must be construed broadly so as not to exclude any material that is relevant or "appears reasonably calculated to lead to the discovery of other admissible evidence." Utah R. Civ. P. 26(B)(1).

B. Each request must be answered independently of the other requests.

C. You have a duty to produce all documents indicated in the categories below: "[R]equests for production should not be read or interpreted in an artificially restrictive or hypertechnical manner to avoid disclosure of information failry covered by the discovery request, and to do so is subject to appropriate sanctions." Fed. R. Civ. P. 37(a) advisory committee's note (1993).

Production Requests

Please produce the following documents by providing legible photocopies of the originals to Plaintiff's attorneys within thirty days after service of the requests upon you.

1. Any documents that relate or refer to the Plaintiff's claims, your defenses, and/or your counterclaims in this Action.

OBJECTION Overly broad and vague. The blanket character of the request makes it impossible to discern or comply with.

2. Any agreements, applications, statements, receipts, proofs of payment or other documents related to the Account.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

3. Any correspondence with CAPITAL ONE BANK (USA), N.A. or the Plaintiff regarding the Account or this Action.

Defendant has no such correspondence.

4. Cancelled checks or check book stubs which indicate any payment on the Account in question.

Defendant has no such records.

5. Any correspondence with anyone related to this account, including without limitation, any witnesses, processionals, and experts (whether they have been retained to testify or not).

OBJECTION Repetitive of Interrogatories. Asked and answered.

6. Any documents identified in your answers to the Interrogatories above.

No such documents were identified, therefore defendant has no such obligation.

7. Any documents you may present as evidence or exhibits in a trial of this Action.

OBJECTION Premature and violative of the work product doctrine at this time.

8. Any reports or exhibits prepared by any expert or lay witnesses pertaining to this Action.

Defendant has no such documents at this time, but reserves the right to amend.

9. Any documents relating to any witness you intend to call at trial.

OBJECTION Repetitive and unnecessary.

REQUESTS FOR ADMISSION

Instructions

A. The following requests for admission will be deemed admitted if not responded to within 30 days after service.

B. The purpose of requests for admission is "to establish admission of facts about which there is no real dispute" for the purpose of "expediting and streamlining litigation." 7 Moore's Federal Practice, 36.02[1] (Matthew Bender 3d ed.). You have an obligation to cooperate in this process.

C. Refusing to answer or simply denying a request for admission on grounds that it deals with a question of law is improper: you may be asked to admit the "truth of any matters within the scope of Rule 26(B) set forth in the request that relate to statements or opinions of fact or of the application of law to fact." Utah R. Civ. P. 36(a)(1).

D. "A denial shall fairly meet the substance of the requested admission, and when good faith requires that [you] qualify [your] answer or deny only a part of the matter of which an admission is requested, [you] shall specify so much of it as is true and qualify or deny the remainder." Utah R. Civ. P. 36(a)(2).

E. You may not give lack of information or knowledge as a reason for failing to respond unless you have "made reasonable inquiry and that the information known or readily obtainable by him is insufficient to enable him to admit or deny." Utah R. Civ. P. 36(a)(2).

Requests for Admission

Please admit the following facts:

1. Admit you entered into a contract with CAPITAL ONE BANK (USA), N.A. creating a credit account.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

2. Admit you agreed to pay for the credit balance on the Account.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached. Defendant cannot speculate as to the contents of an agreement he / she does not have.

3. Admit you used, or authorized the use of, the Account to obtain goods, services, or money.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

4. Admit you received periodic written statements which reflected each transaction, including purchases and/or cash advances, finance charges, late charges, and payments made on the Account which is the subject of this law suit.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any statements which would allow defendant to respond were attached.

5. Admit you did not dispute, in writing, any charges made on said Account or the application of any of the payments to said account within sixty days.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached. Absent the agreement which may or may not establish any such requirements, defendant cannot admit or deny.

6. Admit you failed to make payments pursuant to the terms of the credit agreement.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

7. Admit you are indebted to Plaintiff as the assignee of CAPITAL ONE BANK (USA), N.A. for the full Account Balance stated above.

DENIED Defendant avers he / she owes nothing to Plaintiff. Assignment is a matter for plaintiff to prove at trial.

8. Admit you agreed to pay interest on the Account Balance at the rate of 10.00% per annum, plus any additional court costs, both pre and post judgment, and attorney fees incurred to enforce the agreement.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

I like this…..they are actually saying the interest rate for this account should have been 10%. The other part about fees, etc is entirely separate as I see it.

9. Admit you have not evidence to disprove or defend against Plaintiff's claims in the Action.

OBJECTION Argumentative, calls for impressions of counsel, speculative, and premature.

10. Admit you have no evidence indicating that the account in question was not assigned to Plaintiff.

OBJECTION Argumentative, calls for impressions of counsel, speculative, and premature. Defendant has no clue as to the business dealings of junk debt buyers. Assignment is a matter for plaintiff to prove, not for defendant to disprove.

Edited by legaleagle
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1. Admit you entered into a contract with CAPITAL ONE BANK (USA), N.A. creating a credit account.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

You omitted:

A party may serve upon any other party a written request to admit the truth of any discoverable matter set forth in the request, including the genuineness of any document.

The defendant is being asked to admit whether he entered into a contract, not whether a certain document is what it purports to be.

This is yet another response that will do nothing but expose the defendant to a Rule 37 motion.

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Request for Production of Documents

2. Any agreements, applications, statements, receipts, proofs of payment or other documents related to the Account.

OBJECTION Pursuant to Rule 36 (a) (1) which states in pertinent part: "Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying." No copies of any documents which would allow defendant to respond were attached.

Why would you object to a Rule 34 rerquest to produce by pointing to Rule 36?

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A party may serve upon any other party a written request to admit the truth of any discoverable matter set forth in the request, including the genuineness of any document

They may ask this, but the genuineness of a document cannot be admitted without attaching a copy of the document which is supposed to be validated per Rule 36 (a) (1). How does the defendant know what they are validating? Maybe the agreement says you get prison time if you don't pay. How would she / he know? The request requires validation of a contract which at this point is alleged to have been entered into. This is a fishing expedition. If they had the "contract" with her / his signature, they wouldn't be asking this question. It's a little legal parsing, which you and I enjoy, but will a credit collections lawyer go this far?

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Why would you object to a Rule 34 rerquest to produce by pointing to Rule 36?

You may have me on this one. My take was "the account." There was no evidence of the account attached. Perhaps she / he would be better advised to object based upon the information being equally available to the plaintiff through their business records. If they had this, they would not be asking for it. Good point.

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