Being sued by Midland in AZ.

[catgirl1231]

Hello, everyone!

Per the advice of MarvinArizona on YouTube, I have decided to post my case on here in hopes of getting some advice. Basically, I'm not sure what to do next. I want to send a request for production of documents because I know they probably don't have them, but I'm not sure when the appropriate time for that is. Anyway, here are the details of my case:

1. Who is the named plaintiff in the suit?

Midland Funding LLC.

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.)

Jerold Kaplan Law Office.

3. How much are you being sued for?

$3,616.64.

4. Who is the original creditor? (if not the Plaintiff)

Allegedly Household Bank/HSBC.

5. How do you know you are being sued? (You were served, right?)

Served summons on 3/16/12.

6. How were you served? (Mail, In person, Notice on door)

In person at my home.

7. Was the service legal as required by your state?

I think so...

Process Service Requirements by State - Summons Complaint

Not sure exactly what this means...

8. What was your correspondence (if any) with the people suing you before you think you were being sued?

None that I am aware of. Moved around a lot and could have possibly gotten lost in the shuffle if anything were ever sent to me.

9. What state and county do you live in?

Maricopa County, Arizona

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations)

According to my credit report, the last alleged activity/payment on the account was 6/2008.

11. What is the SOL on the debt?

Statute of Limitations on debts I believe for open accounts in AZ is 3 years.

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name).

-Served 3/16/12.

-Answered 2 days after receiving the summons via CMRR (denied everything except who I am.) Sent copies to Plaintiff's lawyer as well.

-Sent DV letter in an attempt to get information about the debt to Plaintiff's lawyer CMRR + copy to the court same day as Answer.

-1st Mediation set for 6/26/12 (Found out today from the court website.)

13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?)

Only recently have I found out about this debt, so no.

14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late.

No, only sent one recently.

15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit?

20 days is the cutoff for filing an Answer, and no, I have not received anything other than the summons so far. They are just claiming that I owe 3,616.64 and that my husband is also responsible due to the AZ community property law. Thing is we never accrued any debt in our marriage, and the debt from what I can see occurred in 2008 (which is beyond SOL in this state, but I haven't mentioned that to them yet) and we were living in FL at the time (not sure if that makes any difference.)

16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits.

An Affidavit from someone in MN (which also happens to share the same address as one of Midland's operation in MN ) and a vague, poorly done copy of the cc agreement. Not real evidence (a joke,) but pretty common from what I've read of people's situations on this forum.

[Coltfan1972]

http://www.creditinfocenter.com/forums/there-lawyer-house/313112-all-inclusive-ive-been-sued-contacted-midland-whats-next-help-me.html#post1158071

[BV80]

1stStep and Beergoggles (who's going through a JDB suit right now) are from your state. They can help with AZ specific rules.

We can all help with suggestions for responses to the Complaint.

[Beergoggles]

I can tell you keep a eye on the court docket, These guys Kaplan Law have a habit of not mailing you things until about 3 weeks after the fact and then it might be too late. Start working on your Opposition to Summary Judgement because its not if they file it , its when they file it. Send discovery and send it soon. I have had there affidavits precluded already they failed to respond to the motion.

[catgirl1231]

Okay, the info you guys provided was indeed helpful to some degree, but what your help is lacking is examples of the forms. I do not understand at all how to create/submit the proper forms, for example the request for production of documents, interrogatories, admissions, etc. And if they file a motion for summary judgement (as BeerGoggles has mentioned they might do) before mediation, how exactly do I respond to that? My husband & I have read the AZ rules of civil procedure, but don't understand them because they are just a jumbled mess in PDF format. We have tried to consult with a local consumer debt lawyer who handles cases from Midland, but in his response to our email for advice he said he wants $$$, which we don't have. Seriously thinking of just filing Chapter 7 Bankruptcy (when we magically somehow get the money to do so) because we have some other debts that we just can't pay.

[BV80]

Okay, the info you guys provided was indeed helpful to some degree, but what your help is lacking is examples of the forms. I do not understand at all how to create/submit the proper forms, for example the request for production of documents, interrogatories, admissions, etc. And if they file a motion for summary judgement (as BeerGoggles has mentioned they might do) before mediation, how exactly do I respond to that? My husband & I have read the AZ rules of civil procedure, but don't understand them because they are just a jumbled mess in PDF format. We have tried to consult with a local consumer debt lawyer who handles cases from Midland, but in his response to our email for advice he said he wants $$$, which we don't have. Seriously thinking of just filing Chapter 7 Bankruptcy (when we magically somehow get the money to do so) because we have some other debts that we just can't pay.

Any court document would be prepared using the same court header that Midland used for their Complaint. The court head has

Midland Funding, Plaintiff

v.

Catgirl1231

It also has the title, case number and court name. That's the court header. The only thing you'd change would be the title. For your response to the Complaint, the title could be "Defendant's Answer to Plaintiff's Complaint". For a request for documents, the title could be "Defendant's Request for Production of Documents."

Read your court's Rules of Civil Procedure. It will explain about answers and the discovery process.

All that being said, if you have debts that are not JDB related and which you might have trouble defending in court, bankruptcy may be a better option for you. It can take some burdens off your shoulders and provide a fresh start.

[catgirl1231]

Any court document would be prepared using the same court header that Midland used for their Complaint. The court head has

Midland Funding, Plaintiff

v.

Catgirl1231

It also has the title, case number and court name. That's the court header. The only thing you'd change would be the title. For your response to the Complaint, the title could be "Defendant's Answer to Plaintiff's Complaint". For a request for documents, the title could be "Defendant's Request for Production of Documents."

Read your court's Rules of Civil Procedure. It will explain about answers and the discovery process.

All that being said, if you have debts that are not JDB related and which you might have trouble defending in court, bankruptcy may be a better option for you. It can take some burdens off your shoulders and provide a fresh start.

Well, here's the thing: the main reason I am discouraged & deciding whether to fight it or not is because the particular ''judge'' I have is a complete jerk. He has a criminal history himself, was going to resign in 2011, but didn't for some reason (did research on what kind of person he is, and the results were not good. Lots of local news articles on how he beat up his wife/violated probation.) Looking back at all the cases at my particular court shows my judge favors the junk debt buyers, even if the defendant(s) decided to fight back. And as far as my old debts are concerned, according to my credit report they've all but one been charged off or sold to collections (I have 2 that are now with LVNV Funding, worried they are going to sue me too.) I don't even have a job, I haven't had a steady job in 4 years. I am at my wit's end here. Not sure what else to do...

[BV80]

Well, here's the thing: the main reason I am discouraged & deciding whether to fight it or not is because the particular ''judge'' I have is a complete jerk. He has a criminal history himself, was going to resign in 2011, but didn't for some reason (did research on what kind of person he is, and the results were not good. Lots of local news articles on how he beat up his wife/violated probation.) Looking back at all the cases at my particular court shows my judge favors the junk debt buyers, even if the defendant(s) decided to fight back. And as far as my old debts are concerned, according to my credit report they've all but one been charged off or sold to collections (I have 2 that are now with LVNV Funding, worried they are going to sue me too.) I don't even have a job, I haven't had a steady job in 4 years. I am at my wit's end here. Not sure what else to do...

It wouldn't hurt to get a free consultation with a bk attorney right away. That way you'd know where you stand. A free consultation does not mean you have to hire that attorney. You could choose to get a second opinion with another attorney.

If you choose to meet with an attorney, he'll tell you what documentation to bring to the meeting. I'd also prepare by writing down the name of every single entity to whom I owe a debt and the amount of the debt. It might help to bring a copy of your credit report. He'll want to know about property that you own...car, home, etc. and their value.

[Beergoggles]

The search function is your friend, just type in those particular things and you will find so much information. Do not file anything until you ask for advice or critique of it. Start reading up on Summary Judgements because like I said before its not if its when. Read the civil rules of procedure and then read it again and again and again. Read the rules of evidence and again and again ( Hearsay, Business records). I have read them 3 times and am starting to read them again. I have to just to maybe understand it all. Mediation is nothing to worry about, the lawyer will probably be on the phone, the mediator will try to get you to admit to the debt, do not! Do not admit to anything unless its your name and maybe your address. From my experience the mediator is on the plaintiffs side, but that was my mediation not yours. Mediation is trying to settle out of court. Just take a deep breath and focus. The wheels of justice move slowly, this will drag on and on until the last day. You will have ups and downs. Its not easy. read these forms here is a good one to start with,

http://www.creditinfocenter.com/forums/there-lawyer-house/311242-lack-standing.html

and

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

Just ask questions and study!

BG

Okay, the info you guys provided was indeed helpful to some degree, but what your help is lacking is examples of the forms. I do not understand at all how to create/submit the proper forms, for example the request for production of documents, interrogatories, admissions, etc. And if they file a motion for summary judgement (as BeerGoggles has mentioned they might do) before mediation, how exactly do I respond to that? My husband & I have read the AZ rules of civil procedure, but don't understand them because they are just a jumbled mess in PDF format. We have tried to consult with a local consumer debt lawyer who handles cases from Midland, but in his response to our email for advice he said he wants $$$, which we don't have. Seriously thinking of just filing Chapter 7 Bankruptcy (when we magically somehow get the money to do so) because we have some other debts that we just can't pay.

[1stStep]

Answer, deny everything, and send discovery...the first thing I'd ask for is a complete, legible copy of the cardholder agreement...

[Coltfan1972]

Well, here's the thing: the main reason I am discouraged & deciding whether to fight it or not is because the particular ''judge'' I have is a complete jerk. He has a criminal history himself, was going to resign in 2011, but didn't for some reason.

This is just an excuse to quit and lose, plain and simple. You play the hand you are delt. Sheer determination and a will to never lose will defeat and overcome these type of obstacles.

At the end of the day, no judge wants to be overturned on appeal, and it is a nightmare if the appeal is won by a pro-se, non-atty litigant. You can't use this as an excuse. You tie the judge's hands and force them to rule in your favor, no matter how bad they don't want to rule in your favor.

"There is nothing that can deter a determined man/woman from his/her resolve to succeed and win, for He/She is willing to annihilate anything that stands in his/her way."

[Rivertime]

Listen to there advice, it's good advice!

Look at the bright side, if you were to somehow loose your fight, you could always do your BK after they won the case. At least you cost them a bunch of money!

Good Luck,

rt

[legaleagle]

Everything you need can be found on line. If you intend to fight, we can help. If not, well, that's your decision. It can be intimidating, because this happens fast. That's what they count on. You can file for extensions of time for just about anything, which gives you time to study. you MUST understand the rules of procedure or you'll never have a chance. Most of us were in this same spot ourselves at one time or another.

[AmyBlueClue]

You should really read the findings of the Maryland Office of the Commissioner of Financial Regulation in case number DFR-FY2012-012. It is about 40 pages but it goes into detail on how exactly LVNV Funding LLC (and other Sherman owned companies) do business. I have read it several times. The most interesting stuff starts about half way through the case document. You can read or download the case document in PDF format from the State Of Maryland web site. I am new here so they will not allow me to post any links yet but just go to Google and search on "Maryland DFR-FY2012-012" or "LVNV DFR-FY2012-012" and you will find it.

[usagi555]

You should really read the findings of the Maryland Office of the Commissioner of Financial Regulation in case number DFR-FY2012-012. It is about 40 pages but it goes into detail on how exactly LVNV Funding LLC (and other Sherman owned companies) do business. I have read it several times. The most interesting stuff starts about half way through the case document. You can read or download the case document in PDF format from the State Of Maryland web site. I am new here so they will not allow me to post any links yet but just go to Google and search on "Maryland DFR-FY2012-012" or "LVNV DFR-FY2012-012" and you will find it.

Reading that for general info on JDBs will show people what to look for, but OP is dealing with Midland, not a Sherman subsidiary.

[catgirl1231]

So what you guys are saying is, even if they do happen to win, I can still file an appeal to stop the ruling/file bankruptcy after the fact, and that will stop them from garnishing my husband or I's paycheck? I'm sorry if I seem ignorant or stupid, I'm just a fairly young person trying to find my way in life (my chosen career at the moment is nursing, I have dreams of going back to school for veterinary science, so I don't really know anything about law.) I don't have a job right now, but have been actively looking for one, but now I am basically scared out of my mind because I feel like if I have an income coming in, all of these people I allegedly owe money to will show up at my doorstep demanding it.

I really appreciate your support & encouragement, I really do. This forum & my husband are all I have right now. I plan to do more research & not give up so easily thanks to what you guys said. I've just been really depressed about this the past few days. I haven't eaten anything in 48 hours & am beginning to feel like I am losing my mind. I can't talk to anyone in my family about this either, because they have a very bad habit of judging people based on their financial situation. My mom even said she had to change her phone number because she was getting calls from debt collectors for me, and she said it in a really negative way. She herself filed for bankruptcy because of my mentally-ill father racking up a bunch of debt, and she says that is the reason she divorced him So if my family knew what was going on with this right now, it's almost guaranteed they'd judge me harshly.

[1stStep]

So fight it...

Midland is beatable - attack their standing to sue and you can pretty much win the case.

[Rivertime]

So fight it...

Midland is beatable - attack their standing to sue and you can pretty much win the case.

The people on this forum will help you. There are some on here that really know what they're doing and they are true saints...

rt

[Coltfan1972]

To answer your question, yes, you can still appeal and still file BK. In fact, if you are going to file BK, then fight like hell against them. A BK wipes the debt away even if it is a judgment and even if you are getting garnished.

Just relax and you will be fine. Midland is very beatable. I know a lady in Florida that did not even know where the courthouse was located. She took on another junk debt buyer and not only beat them, but won a counter claim. She just finished an interview with a local TV station that was going through court records and noticed how she was one of the .05% that actually fight.

I met her on this board and looked at all her court papers and most importantly the judgement papers. I can assure you that she had zero clue about this process.

You get going against scum like Midland, get a little confidence behind you, and next thing you know, you are destroying them.

[legaleagle]

For this amount of money, I think arbitration may be the way to go. You invoke this through the cardholder agreement, it usually costs them more than they can get.

[catgirl1231]

So, I received the official mediation date paper in the mail. Says no one can appear by phone, but from what I've read of cases with Midland, they always do, even if their attorney's office is in the area.

Also received what appears to be their disclosure statement. Basically it says that I entered into a credit card agreement with Plaintiff/Plaintiff's assignor, Midland, and that there was a breach of contract. It states on the 2nd page under a list of witnesses that an ''authorized representative'' of Plaintiff/Plaintiff's assignor under whose supervision the account is kept at or near at the time of transaction (not sure what this means.) Then it goes on to say ''It is expected that the representative will testify as to the nature of the contract, the credit granted to the defendant(s), transactions on the credit card and the current outstanding balance including interest, attorneys fees, and costs.''

Then on the last page it lists documents and other information. It says:

A. Affidavit of balance owed; and

B. Household Bank Credit card agreement.

Then it says this at the bottom: ''Investigation continues, Plaintiff is searching it's records for additional statements of account regarding this matter and will update it's disclosure statement when these statements are found.''

Translation: They likely don't have anything else, right?

How should I respond to this? I don't have anything to disclose. I wish there was a way to scan/upload the paperwork so that you can see it to better assist me. Is this a good time to send Request for Production of Documents/Initiate Discovery? I read (I believe it was BeerGoggles case) where the court said he could file the requests at mediation. Is this advisable?

[legaleagle]

It states on the 2nd page under a list of witnesses that an ''authorized representative'' of Plaintiff/Plaintiff's assignor under whose supervision the account is kept at or near at the time of transaction (not sure what this means.)

It means nothing, because it is compounded and unclear. There is no legal definition of /, sorry. What does "Plaintiff/Plaintiff's assignor" mean? To which one does the plaintiff refer? This is a cheap tactic. They are going to produce a witness that works for Midland, who is going to swear that he is familiar with Midland's records, and that they are true and accurate to the best of his knowledge. The only problem with that is that Midland is not the OC, so this goes out the window. If they produce a witness from the OC, however, who will swear to this same thing but for the OC, that's a bit harder to defeat. They'll never do this of course, because they won't spend the money.

''Investigation continues, Plaintiff is searching it's records for additional statements of account regarding this matter and will update it's disclosure statement when these statements are found.''

Translation: We don't have what we need to win, but we hope you're stupid enough to believe we can find it later. We won't, because we won't pay for it and the OC probably doesn't even have it because half their employees are on crack and can't find their way to work in the morning, but we could get lucky. One of these minimum wage morons might pass out and fall onto his computer, hit exactly the right button with his face, and voila, here comes all the documentation.

I don't think you respond to a letter. Just show up and raise these issues.

[catgirl1231]

It states on the 2nd page under a list of witnesses that an ''authorized representative'' of Plaintiff/Plaintiff's assignor under whose supervision the account is kept at or near at the time of transaction (not sure what this means.)

It means nothing, because it is compounded and unclear. There is no legal definition of /, sorry. What does "Plaintiff/Plaintiff's assignor" mean? To which one does the plaintiff refer? This is a cheap tactic. They are going to produce a witness that works for Midland, who is going to swear that he is familiar with Midland's records, and that they are true and accurate to the best of his knowledge. The only problem with that is that Midland is not the OC, so this goes out the window. If they produce a witness from the OC, however, who will swear to this same thing but for the OC, that's a bit harder to defeat. They'll never do this of course, because they won't spend the money.

''Investigation continues, Plaintiff is searching it's records for additional statements of account regarding this matter and will update it's disclosure statement when these statements are found.''

Translation: We don't have what we need to win, but we hope you're stupid enough to believe we can find it later. We won't, because we won't pay for it and the OC probably doesn't even have it because half their employees are on crack and can't find their way to work in the morning, but we could get lucky. One of these minimum wage morons might pass out and fall onto his computer, hit exactly the right button with his face, and voila, here comes all the documentation.

I don't think you respond to a letter. Just show up and raise these issues.

LoL, thanks for the laugh, LE! Your info regarding their ''witness'' statement was helpful too. I'm going to look further into whether I have to respond directly to their disclosure statement. I am pretty sure I only have to submit my own, because this is what it says on my notice to appear for mediation:

Paragraph 12. Disclosure statements: ''Each party shall be requested to comply with Rule 26.1, Rules of Civil Procedure, regarding the prompt disclosure of information. The parties shall serve upon each other their initial disclosure statement not later than (40) days after the answer having been filed, or at the initial date set for mediation, whichever date is earlier. Any party failing to timely disclose information required by Rule 26.1 shall be subject to sanctions as provided at Rules 37C and D, Rules of Civil Procedure.''

Also, it says this on my mediation paperwork about Discovery motions:

Paragraph 16. ''No motion for order compelling Disclosure or Discovery will be considered or scheduled unless the moving party shall have first complied with Rule 37(a) (2) C, Rules of Civil Procedure.''

I read this particular rule they mention, but it still doesn't make sense to me. Can anyone in AZ who has been through this process with Midland shed some light on when I can initiate Discovery/Production of Documents or not, and how to go about it? I don't want to screw this up & wait until June 26th's mediation to get my ducks in a row (unless I have to in order to not piss off the court/follow the rules.) But at the same time, I want to hit them where it hurts now in order to win.

[Beergoggles]

Yes the court should give you the proper paperwork and the directions and rules for them. Now they do not give you the entire Civil Rules of Procedure. Disclosure is them telling you what they have and you telling them what you have. I had nothing so I said I had no evidence. What evidence am I supposed to provide? They are suing me that's their job. You will need to file discovery soon. They most likely will not respond to it though. Good for you. They will file a motion to appear telephoniclly at everything. If they could get away with it at trial I am sure they would try then too!

You can send discovery at anytime

16 A.R.S. Rules of Civil Procedure, Rule 34(

The requests may, without leave of the court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party. The requests shall set forth the items to be inspected either by individual item or by specific category, and describe each item and specific category with reasonable particularity. The request may specify the form or forms in which electronically stored information is to be produced. The requests(s) shall not, without leave of court, cumulatively include more than ten (10) distinct items or specific categories of items. Each request shall specify a reasonable time, place, and manner of making the inspection and performing the related acts. If a party believes that good cause exists for more than ten (10) distinct items or categories of items, that party shall consult with the party upon whom a request would be served and attempt to secure a written stipulation to that effect. The party upon whom a request is served shall serve a written response within 40 days after the service of the request, except that a defendant may serve a response within 60 days after service of the summons and complaint upon that defendant, or execution of a waiver of service by that defendant. The court may allow a shorter or longer time. The response shall state, with respect to each item or category, that inspection and related activities will be permitted as requested or identify the reasons for any objection, including any objection to the requested form or forms for producing electronically stored information,. If objection is made to part of an item or category, the part shall be specified. If objection is made to the requested form or forms for producing electronically stored information--or if no form was specified in the request--the responding party must state the form or forms it intends to use. The party submitting a request may move for an order under Rule 37(a) with respect to any objection to or other failure to respond to the request or any part thereof, or any failure to permit inspection as requested. Unless the parties otherwise agree, or the court otherwise orders:

(1) a party who produced documents for inspection shall produce them as they are kept in the usual course of business or shall organize and label them to correspond with the categories in the request;

(2) if a request does not specify the form or forms for producing electronically stored information, a responding party must produce the information in a form or forms in which it is ordinarily maintained or in a form or forms that are reasonably usable; and

(3) a party need not produce the same electronically stored information in more than one form.

[catgirl1231]

Yes the court should give you the proper paperwork and the directions and rules for them. Now they do not give you the entire Civil Rules of Procedure. Disclosure is them telling you what they have and you telling them what you have. I had nothing so I said I had no evidence. What evidence am I supposed to provide? They are suing me that's their job. You will need to file discovery soon. They most likely will not respond to it though. Good for you. They will file a motion to appear telephoniclly at everything. If they could get away with it at trial I am sure they would try then too!

You can send discovery at anytime

16 A.R.S. Rules of Civil Procedure, Rule 34(

The requests may, without leave of the court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party. The requests shall set forth the items to be inspected either by individual item or by specific category, and describe each item and specific category with reasonable particularity. The request may specify the form or forms in which electronically stored information is to be produced. The requests(s) shall not, without leave of court, cumulatively include more than ten (10) distinct items or specific categories of items. Each request shall specify a reasonable time, place, and manner of making the inspection and performing the related acts. If a party believes that good cause exists for more than ten (10) distinct items or categories of items, that party shall consult with the party upon whom a request would be served and attempt to secure a written stipulation to that effect. The party upon whom a request is served shall serve a written response within 40 days after the service of the request, except that a defendant may serve a response within 60 days after service of the summons and complaint upon that defendant, or execution of a waiver of service by that defendant. The court may allow a shorter or longer time. The response shall state, with respect to each item or category, that inspection and related activities will be permitted as requested or identify the reasons for any objection, including any objection to the requested form or forms for producing electronically stored information,. If objection is made to part of an item or category, the part shall be specified. If objection is made to the requested form or forms for producing electronically stored information--or if no form was specified in the request--the responding party must state the form or forms it intends to use. The party submitting a request may move for an order under Rule 37(a) with respect to any objection to or other failure to respond to the request or any part thereof, or any failure to permit inspection as requested. Unless the parties otherwise agree, or the court otherwise orders:

(1) a party who produced documents for inspection shall produce them as they are kept in the usual course of business or shall organize and label them to correspond with the categories in the request;

(2) if a request does not specify the form or forms for producing electronically stored information, a responding party must produce the information in a form or forms in which it is ordinarily maintained or in a form or forms that are reasonably usable; and

(3) a party need not produce the same electronically stored information in more than one form.

Thank you for responding to my question, BeerGoggles. So in doing my Disclosure, do I follow the same format as their Disclosure, or do I simply create my own just basically saying I have nothing to Disclose?

And when I start Discovery, do I have to notify the court in any special way (for example, with a motion) or can I just send the paperwork straight to the attorney's office (CMRR) the Request for Production, Interrogatories, etc.?

Also, I tried answering your PM, but because I don't have enough posts yet I couldn't