My RA/RP toMidland to be reviewed-Rogs next post

[backinthe50's]

Request to Produce:

1. The original signed application establishing the account.

2. Charge slips bearing Defendants signature which established use of the alleged account.

3. The original written agreement in which defendant allegedly assented to the terms of the account.

4. A complete history of the alleged account from day one, establishing the legitimacy of the balance sought.

5. Any recording or transcript of any recording of telephone calls in which defendant disputed the alleged amount owed.

6. Any cancelled checks or copies of cancelled checks, or other verified payments on the alleged account Plaintiff intends to introduce at trial.

7. All contracts entered into between Plaintiff and Defendant, or between Defendant and any previous owner or holder of the contract in reference to this lawsuit.

8. All documents related to the transfere, purchase, or assignment regarding the alleged debt.

Request for Admissions:

1. Admit the Plaintiff purchases defaulted debt as a regular course of business.

2. Admit the Plaintiff is not the original creditor of the alleged debt which is the subject of this lawsuit.

3. Admit the Plaintiff is not affiliated or subsidery of CHASE BANK USA, N.A.

4. Admit that the Plaintiff does not now nor has ever originated records for Chase Bank USA, N.A. that would be maintained by that company in their regular course of business.

5. Admit that Plaintiff does not calculate or maintain records for the benefit of Chase bank USA, N.A.

6. Admit that Plaintiff does not have an application for an extension of credit from the Defendant.

7. Admit that Plaintiff does not have an application for an extension of credit from the Defendant exhibiting a Signature from the Defendant.

8. Admitthat the Plaintiff does not have access to all the records created and maintained by Chase Bank USA, N.A. that pertain to the alleged account that is the subject of this lawsuit

9. Admit that Plaintiff has submitted all documentation in Plaintiffs posession related to the alleged debt which is the subject of this lawsuit.

10. Admit that Plaintiff has reported this alleged account as a negative report on the Defendants credit report and reported said account as a new account with an opening date of 02/2012.

[BV80]

I would send admissions requests after receiving their response to my docs request. The reason is that you can then tailor your admissions requests based upon the documents they sent AND didn't send, if necessary.

Just make sure your rules allow requests to be sent at different times.