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HELP! How do I respond to 1st Request for Production of Documents?

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I have to respond this week. Thanks to the help on this forum, I know how to respond to the Requests for Admissions. But how do I respond to the First Request for Production of Documents? It says I must provide:

1. Any documents that relate or refer to the Plaintiff's claims or your defenses in this action.

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

3. Any correspondence with (Original Creditor) or the Plaintiff regarding the Account or this Action.

4. Any correspondence with anyone related to this Account, including without limitation, witnesses, professionals, and experts (whether they have been retained to testify or not)/

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

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

If I'm denying everything in the Request for Admissions (like I did in my Answer, since they have provided NOTHING to prove this account belongs to me), then how can I provide any documents? But I have to respond, right?

Should I ask for an extension on this? Can I ask for an extension?

Should I be asking them for docs yet, or wait till I get these responses off?


Edited by Dovetail630
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(I'm very new on this forum.)

I think that is an excellent question, I'm eager to see what others have to say.

I have the same questions.

I also wonder, are you allowed to object to the request (like they say you can do with interrogatories)?

I also wonder if we (the ones being sued) are allowed to send them "affirmations".

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It's a trap, they have no evidence and hope you'll be stupid enough to provide it for them. I would answer this way:

"After a diligent search, defendant has none of the requested documents. Per the rules of procedure, defendant reserves the right to amend should such documents become avaiable."

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