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Responding to Product of Documents in California

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Can the following language be used in California Superior Court when responding to a debt collectors request for production of documents?

"Defendant is unaware of any such documents and therefore cannot produce said documents."

If not, what is the appropriate legal response for California? Thanks

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Legalese is pretty much standard in any court. if you don't have what they are asking for, just answer this way:

"Defendant, after a reasonable search of his records, does not have the requested documents. Defendant reserves the right to amend his response per the rules of civil procedure should such documents become available."

I bet they are asking for all the stuff they need to prove account stated. Statements, cancelled checks, etc. Don't give it to them.

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