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josetorres

Help with INTERROGATORIES

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Let me start by apologizing if I'm not following correct procedures.

My ordeal with Crap1 started early this year when I started to receive statements with an existing balance and in my name and address. I have never had an account with crap1. I have never applied or accepted any accounts with them.

The first statement I shredded. The next statement I called their customer service. Informed them of the issue. They couldn't understand how this happened but assured me that it would be taken care of.

I didn't receive a statement for I guess 2 months. Then received another and was informed that I must pay the account. I told them they could stick it. Ran credit reports and the account was on there with an existing balance. Disputed the accounts and was told that they wont be removed. Next statement I also received a call from their collections telling me to pay. I tried to explain that I don't have an account. That the statements started showing up with an existing balance and not ever any charges. Only to receive threats. I hung up. Later received calls threatening garnishment, embarrassment and so on. I agreed to pay $100 under duress and fear of my job being compromised. Statements stopped and didn't get anymore calls.

Then I received summons for court on the account. I answered summons and disputed the account.

Now I have received interrogatories and need to respond. Just wanting to ask if my response would suffice. Not worried about admission answers, but more of other statements:

1. State with factual particularity the basis for your denial of each allegation in the Complaint that you deny.

Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.

2. Identify all documents that you assert constitute the contractual agreement(s) between the parties.

Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.

3. Identify the number of payments and amount of every payment made toward the underlying contract by you, or made by any other party on your behalf.

Defendant’s response: Defendant objects to the request as vague or ambiguous.

4. Identify all documents and/or correspondence either sent to, or received from, the Plaintiff or any of its agents or predecessors in interest relevant to this matter.

Defendant’s response: Defendant not in possession of suggested documents.

5. Identify all persons whom you contend have knowledge of the facts which evidence or tend to support the denials, assertions and allegations as set forth in your Answer, stating for each such person his or her name, address, telephone number, and provide a brief statement of the facts as to which each such person has knowledge.

Defendant’s response: Defendant objects to the request as vague or ambiguous.

6. Identify all documents, by title and date, which you contend evidence or tend to support the denials, assertions and allegations as set forth in your Answer, and provide the name, address and telephone number of the current custodian for each such document.

Defendant’s response: Defendant not in possession of suggested documents.

7. State with factual particularity the basis for your denial of any Request for Admission of Fact that you deny.

Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.

8. State with factual particularity any charges you disputed within sixty (60) days of their appearance on your monthly statement, the basis of any such dispute and identify all documents that support any such dispute.

Defendant’s response: Defendant objects to the request as vague or ambiguous.

9. State the amount you contend you owe Plaintiff and describe how you calculated that amount.

Defendant’s response: Defendant does not owe any amount to Plaintiff because Defendant has never had a contractual agreement with Plaintiff.

10. Identify all documents or other tangible things which you believe prove, support, or constitute evidence of any fact or circumstances supporting Defendant’s answer.

Defendant’s response: Defendant objects to the request as vague or ambiguous.

11. State each and every fact upon which you based your denial of the indebtedness claimed owed by Plaintiff.

Defendant’s response: Defendant does not have any agreements with Plaintiff.

1. Produce copies of any and all correspondence which in any way pertain to this action sent to,

or received from, Plaintiff.

Defendant’s response: Not in possession of suggested documents.

2. Produce copies of any and all documents signed by you and/or the Plaintiff pertaining to this action.

Defendant’s response: Defendant has not signed any documents pertaining to Plaintiff.

3. Produce copies of any and all documents deemed by you to constitute a contract or agreement between the parties.

Defendant’s response: Suggested documents do not exist.

4. Produce copies of any and all checks or other forms of payment used to make payments on the underlying contract either made by you, or made by any other party on your behalf.

Defendant’s response: Defendant not in possession of suggested documents.

5. Produce copies of any and all documents that would support that you disputed the charges within sixty (60) days of their appearance on your monthly statement as required by your cardholder agreement.

Defendant’s response: Defendant does not have any agreements with Plaintiff.

6. Produce copies of any and all documents that you assert would support a denial of any Request for Admission of Fact that you deny.

Defendant’s response: Defendant not in possession of suggested documents.

7. Produce copies of any and all documents that would support any defense, claim or contention asserted by you in your Answer.

Defendant’s response: Defendant not in possession of suggested documents.

8. Produce copies of any and all documents that support your contention that the amount claimed by Plaintiffs incorrect.

Defendant’s response: Defendant not in possession of suggested documents.

Thanks for any help and apologize if excessive.

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  • Answer these questions and you will get help.  You have a uniques situation and possibly there will be other avenues you can take if infact you have never had a CC with Cap1.
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Posted 21 July 2005 - 12:22 PM

For everyone that posts here, it will help us out if you can provide the following information: (revised 02-09-2012)

If you are inquiring about a lawsuit in which you are the defendant (ie you are being sued), you need to answer the following questions (as much as possible):

1. Who is the named plaintiff in the suit?

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

3. How much are you being sued for?

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

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

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

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

Process Service Requirements by State - Summons Complaint

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

9. What state and county do you live in?

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

11. What is the SOL on the debt? To find out:

Statute of Limitations on Debts

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

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

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.

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?

Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits

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

17. Read this article:

Sued by a Debt Collector - Learn How to Fight Debt Lawsuits

====================================================

 

 

 

 

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Please post the complaint and any attached evidence. We need to know what the cause of action is, and what evidence they are going to use.

 

We can then work on your interogs and discovery.....

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Prior to being served summons I sent both, , crap1 and the attorney, a letter demanding validation and proof. If they could not provide the info, to remove tnhe file. Only responses I received was a letter asking me to call them, even though I requested only contact usps (which they ignored). The letters where sent reg mail. Maybe I should have sent signature required. The claim is that I have had an account with them for a few years a stopped paying. The stated balance is aprox 5k. I requested proof of account or purchases and copies of statements. Which none have been received. When I did speak to them on phone, they had my name address, phone and ssn all correct. I suppose that is why the credit bureau refused to remove. The name of the firm is irrelevant, I reside in ga. I would guess that crap1 would be original creditor.

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You are dealing with the Original creditor, validation of debts deos not apply to them.  You are now in court so debt validation means nothing, you need to concentrate on the suit,,,,,

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I see now that validation doesn't mean anything, but shouldn't they have to provide proof of account? Do I need to send them the same admissions and innterogatories request that I was sent? Or, since their lawyers, would they just wiggle around my requests?

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If this is truly a mixup and this is not or ever was your account, and the attorneys are debt collection attorneys, you have a nice FDCPA suit against them.

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From what I can find on them they are a collection group. I truly do not have and have not applied or received an account with them. I dont care about a suit against them except if that is the only way to make them relize its not mine. Do I need to send them the same admissions and innterogatories request that I was sent? Or, since their lawyers, would they just wiggle around my requests?

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Be clear here.....we are trying to establish if you had an account with Cap 1. We don't even know who is suing you, because you didn't answer the 20 questions yet. If this is a junk debt buyer who purchased your account from Cap 1, it's a whole different game. All these banks issue credit cards for other people.....stores, Home Depot, Dell, you name it. The card won't say Cap 1 on it, but they may have issued it. This is what you have to figure out, otherwise we can't help very much.

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I understand that, and ill do my best. But I also know the attorneys would troll these forums also.

 

1. Who is the named plaintiff in the suit?

crap1

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

3. How much are you being sued for?
aprox 5k


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

crap1 I assume

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

served

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


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


8. What was your correspondence (if any) with the people suing you before you think you were being sued?
Asking for statements, charges, purchases, applications, contracts


9. What state and county do you live in?
Ga, Muscogee


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

not outside sol


11. What is the SOL on the debt? To find out:

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or B) 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, no motions, dealing with admissions


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


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.
yes


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?
30 days for admissions response


Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits

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

nothing


 

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If they never had an account with them, and is a bogus collection should't the OP be filing an Identity fraud case with the police and getting a consumer attorney invovled?

 

maybe a complaint to the Georgia AG as well

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You call the AG or go to their web site,,they usually have a form you can file online for complaints.

 

Lets clear up a few things,,,,did you have a credit card with Cap 1?

 

What is the name of the collection agency suing you.?

 

If there was no affidavits or evidence attached to the summons then you should file a motion to preclude ANY and all evidence that they may want to present later.

 

Send them discovery and ask for any and all evidence that they have.

 

What are the exact allegations in the complaint, is it account stated, breech of contract common counts,,,we need to know in order to show you how to defend the case.

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You call the AG or go to their web site,,they usually have a form you can file online for complaints.

 

Lets clear up a few things,,,,did you have a credit card with Cap 1?

 

What is the name of the collection agency suing you.?

 

If there was no affidavits or evidence attached to the summons then you should file a motion to preclude ANY and all evidence that they may want to present later.

 

Send them discovery and ask for any and all evidence that they have.

 

What are the exact allegations in the complaint, is it account stated, breech of contract common counts,,,we need to know in order to show you how to defend the case.

 

 

File a motion to preclude, then send discovery requests?

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Let me start by apologizing if I'm not following correct procedures.

My ordeal with Crap1 started early this year when I started to receive statements with an existing balance and in my name and address. I have never had an account with crap1. I have never applied or accepted any accounts with them.

The first statement I shredded. The next statement I called their customer service. Informed them of the issue. They couldn't understand how this happened but assured me that it would be taken care of.

I didn't receive a statement for I guess 2 months. Then received another and was informed that I must pay the account. I told them they could stick it. Ran credit reports and the account was on there with an existing balance. Disputed the accounts and was told that they wont be removed. Next statement I also received a call from their collections telling me to pay. I tried to explain that I don't have an account. That the statements started showing up with an existing balance and not ever any charges. Only to receive threats. I hung up. Later received calls threatening garnishment, embarrassment and so on. I agreed to pay $100 under duress and fear of my job being compromised. Statements stopped and didn't get anymore calls.

Then I received summons for court on the account. I answered summons and disputed the account.

Now I have received interrogatories and need to respond. Just to ask if my response would suffice. Not worried about admission answers, but more of other statements:

1. State with factual particularity the basis for your denial of each allegation in the Complaint that you deny.

Defendant’s response: Defendant has never had a contractual agreement with Plaintiff. Objection: Plaintiff has attached no evidence of any sort to the complaint, there fore the defendant can not discern whether the allegations are factual of moot . It would call for speculation on the defendants part.

2. Identify all documents that you assert constitute the contractual agreement(s) between the parties.

Defendant’s response: Defendant has never had a contractual agreement with Plaintiff. Objection: The Plaintiff has not provided a contract attached to the summons if Plaintiff is basing their claim on a contractual agreement, the Plaintiff needs to produce a contract that bears the defendants signature.

3. Identify the number of payments and amount of every payment made toward the underlying contract by you, or made by any other party on your behalf.

Defendant’s response: Defendant objects to the request as vague or ambiguous. Objection: Same as number 2

4. Identify all documents and/or correspondence either sent to, or received from, the Plaintiff or any of its agents or predecessors in interest relevant to this matter.

Defendant’s response: Defendant not in possession of suggested documents.

5. Identify all persons whom you contend have knowledge of the facts which evidence or tend to support the denials, assertions and allegations as set forth in your Answer, stating for each such person his or her name, address, telephone number, and provide a brief statement of the facts as to which each such person has knowledge.

Defendant’s response: Defendant objects to the request as vague or ambiguous.

6. Identify all documents, by title and date, which you contend evidence or tend to support the denials, assertions and allegations as set forth in your Answer, and provide the name, address and telephone number of the current custodian for each such document.

Defendant’s response: Defendant not in possession of suggested documents. Objection: Plaintiff is on a fishing expedition, since the Plaintiff did not include a contract signed by the defendant that shows the terms of the contract the Plaintiff is relying on the defendant to prove the Plaintiffs case for them.

7. State with factual particularity the basis for your denial of any Request for Admission of Fact that you deny.

Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.

8. State with factual particularity any charges you disputed within sixty (60) days of their appearance on your monthly statement, the basis of any such dispute and identify all documents that support any such dispute.

Defendant’s response: Defendant objects to the request as vague or ambiguous. Objection: Objection: f cardholders cannot be expected to know whether the information in the monthly statement accurately states what they owe, there cannot be an express or implied agreement that their silence means that they have agreed to the amount claimed is correct.” Id., at 80. In such a consumer credit case, there must be factual allegations that the cardholder agreed to pay the amount alleged to be due, and these factual allegations must be more than mere silence or the card holder’s failure to object.“ Target National Bank v. Samanez, Nos. AR07-009777 and AR06-009418, 156 P.L.J. 76 (Allegheny Cty. C.P. December 26, 2007)

9. State the amount you contend you owe Plaintiff and describe how you calculated that amount.

Defendant’s response: Defendant does not owe any amount to Plaintiff because Defendant has never had a contractual agreement with Plaintiff.

10. Identify all documents or other tangible things which you believe prove, support, or constitute evidence of any fact or circumstances supporting Defendant’s answer.

Defendant’s response: Defendant objects to the request as vague or ambiguous.

11. State each and every fact upon which you based your denial of the indebtedness claimed owed by Plaintiff.

Defendant’s response: Defendant does not have any agreements with Plaintiff. Objection: repeditive, plaintiff has already asked this but used different language

1. Produce copies of any and all correspondence which in any way pertain to this action sent to,

or received from, Plaintiff.

Defendant’s response: Not in possession of suggested documents.

2. Produce copies of any and all documents signed by you and/or the Plaintiff pertaining to this action.

Defendant’s response: Defendant has not signed any documents pertaining to Plaintiff. Objection the plaintiff is fishing again. The question has already been asked but in different language, repeitive, meant to harass.

3. Produce copies of any and all documents deemed by you to constitute a contract or agreement between the parties.

Defendant’s response: Suggested documents do not exist. Objection: Burden of proof is on the Plaintiff to provide a contract, not to rely on the defendant top produce a contract.

4. Produce copies of any and all checks or other forms of payment used to make payments on the underlying contract either made by you, or made by any other party on your behalf.

Defendant’s response: Defendant not in possession of suggested documents.

5. Produce copies of any and all documents that would support that you disputed the charges within sixty (60) days of their appearance on your monthly statement as required by your cardholder agreement.

Defendant’s response: Defendant does not have any agreements with Plaintiff. Objection: cardholders cannot be expected to know whether the information in the monthly statement accurately states what they owe, there cannot be an express or implied agreement that their silence means that they have agreed to the amount claimed is correct.” Id., at 80. In such a consumer credit case, there must be factual allegations that the cardholder agreed to pay the amount alleged to be due, and these factual allegations must be more than mere silence or the cardholder’s failure to object.“ Target National Bank v. Samanez, Nos. AR07-009777 and AR06-009418, 156 P.L.J. 76 (Allegheny Cty. C.P. December 26, 2007)

6. Produce copies of any and all documents that you assert would support a denial of any Request for Admission of Fact that you deny.

Defendant’s response: Defendant not in possession of suggested documents.

7. Produce copies of any and all documents that would support any defense, claim or contention asserted by you in your Answer.

Defendant’s response: Defendant not in possession of suggested documents.

8. Produce copies of any and all documents that support your contention that the amount claimed by Plaintiffs incorrect.

Defendant’s response: Defendant not in possession of suggested documents.

Thanks for any help and apologize if excessive.

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Thanks for your help so far. I plan to file a motion to preclude this week. Will have to ask for help probably. But I will search first. Do the discovery requests need to be filed with the clerks office, or just mailed like they sent me?

This is the answer to their request for documents. Does it look correct?

 

 

1.  Produce copies of any and all correspondence which in any way pertain to this action sent to, or received from, Plaintiff.

Defendant’s response: Not in possession of suggested documents.

 

2. Produce copies of any and all documents signed by you and/or the Plaintiff pertaining to this action.

Defendant’s response: Defendant has not signed any documents pertaining to Plaintiff.

 

3. Produce copies of any and all documents deemed by you to constitute a contract or agreement between the parties.

Defendant’s response: Suggested documents do not exist.

 

4. Produce copies of any and all checks or other forms of payment used to make payments on the underlying contract either made by you, or made by any other party on your behalf.

Defendant’s response:  Defendant not in possession of suggested documents.

 

5. Produce copies of any and all documents that would support that you disputed the charges within sixty (60) days of their appearance on your monthly statement as required by your cardholder agreement.

Defendant’s response: Defendant does not have any agreements with Plaintiff.

 

6. Produce copies of any and all documents that you assert would support a denial of any Request for Admission of Fact that you deny.

Defendant’s response: Defendant not in possession of suggested documents.

 

7. Produce copies of any and all documents that would support any defense, claim or contention asserted by you in your Answer.

Defendant’s response: Defendant not in possession of suggested documents.

 

8. Produce copies of any and all documents that support your contention that the amount claimed by Plaintiffs incorrect.

Defendant’s response: Defendant not in possession of suggested documents.

 

Thanks

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Maybe you never opened an account with Crap1, however Crap1 has over the past few years bought up a few banks like WAMU, HSBS to name a couple. 

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Thats why the OP should send discovery, ask for that info....who exactly do they claim you owe and how they claim you owe that creditor.

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State with factual particularity the basis for your denial of each allegation in the Complaint that you deny.
Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.'

This is ok if you denied such allegation of the complaint

2. Identify all documents that you assert constitute the contractual agreement(s) between the parties.
Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.

OK, ditto

3. Identify the number of payments and amount of every payment made toward the underlying contract by you, or made by any other party on your behalf.
Defendant’s response: Defendant objects to the request as vague or ambiguous.\

I would not use this. I might say. This is not an issue, defendant denies having this account

4. Identify all documents and/or correspondence either sent to, or received from, the Plaintiff or any of its agents or predecessors in interest relevant to this matter.
Defendant’s response: Defendant not in possession of suggested documents.

OK

5. Identify all persons whom you contend have knowledge of the facts which evidence or tend to support the denials, assertions and allegations as set forth in your Answer, stating for each such person his or her name, address, telephone number, and provide a brief statement of the facts as to which each such person has knowledge.
Defendant’s response: Defendant objects to the request as vague or ambiguous.

I prefer to say: tsuch persons work for or in control of plainitff, and have not been identified to defendant yet.

6. Identify all documents, by title and date, which you contend evidence or tend to support the denials, assertions and allegations as set forth in your Answer, and provide the name, address and telephone number of the current custodian for each such document.
Defendant’s response: Defendant not in possession of suggested documents.

Add: Defendant ill amend ths answer as discovery responses from plainitff dictate

7. State with factual particularity the basis for your denial of any Request for Admission of Fact that you deny.
Defendant’s response: Defendant has never had a contractual agreement with Plaintiff.
ok


8. State with factual particularity any charges you disputed within sixty (60) days of their appearance on your monthly statement, the basis of any such dispute and identify all documents that support any such dispute.
Defendant’s response: Defendant objects to the request as vague or ambiguous.

Say instead: not applicable as defendant denies having this account and that was not alleged

9. State the amount you contend you owe Plaintiff and describe how you calculated that amount.
Defendant’s response: Defendant does not owe any amount to Plaintiff because Defendant has never had a contractual agreement with Plaintiff.

OK

10. Identify all documents or other tangible things which you believe prove, support, or constitute evidence of any fact or circumstances supporting Defendant’s answer.
Defendant’s response: Defendant objects to the request as vague or ambiguous.

Defendant cannot answer this interrogaotry as it has no account with plainttr

11. State each and every fact upon which you based your denial of the indebtedness claimed owed by Plaintiff.
Defendant’s response: Defendant does not have any agreements with Plaintiff.

1. Produce copies of any and all correspondence which in any way pertain to this action sent to,
or received from, Plaintiff.
Defendant’s response: Not in possession of suggested documents.

2. Produce copies of any and all documents signed by you and/or the Plaintiff pertaining to this action.
Defendant’s response: Defendant has not signed any documents pertaining to Plaintiff.

3. Produce copies of any and all documents deemed by you to constitute a contract or agreement between the parties.
Defendant’s response: Suggested documents do not exist.

4. Produce copies of any and all checks or other forms of payment used to make payments on the underlying contract either made by you, or made by any other party on your behalf.
Defendant’s response: Defendant not in possession of suggested documents.

5. Produce copies of any and all documents that would support that you disputed the charges within sixty (60) days of their appearance on your monthly statement as required by your cardholder agreement.
Defendant’s response: Defendant does not have any agreements with Plaintiff.

6. Produce copies of any and all documents that you assert would support a denial of any Request for Admission of Fact that you deny.
Defendant’s response: Defendant not in possession of suggested documents.

7. Produce copies of any and all documents that would support any defense, claim or contention asserted by you in your Answer.
Defendant’s response: Defendant not in possession of suggested documents.

8. Produce copies of any and all documents that support your contention that the amount claimed by Plaintiffs incorrect.
Defendant’s response: Defendant not in possession of suggested documents.
 

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Since I originally sent a letter (not certified) to the plaintiffs lawyers before and after being served, asking for copies of contracts with signature, copies of purchases on any proof of account, does that act as discovery? So I can go ahead and file a motion to compel. Or do I need to send a discovery request now?

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Are there forms available on this forum? If not, type in Google "Georgia interrogatory request form". First hit: NorthwestRegisteredAgent.com has general sample forms for discovery requests, motion to compel, summary judgment, etc.

 

Letter forms generally don't work very well. You need to have a Certificate of Service on the motions.

 

You can't file a Motion To Compel until you properly serve the interrogatories w/a COS, and wait 30 days or whatever your state allows. So resend your discovery request in proper form. Add 5 days to the 30 for back & forth mailing, before you entertain a MTC.

 

For a more professional form: Go to davidjreed.com for a sample First Interrogatories. its not dealing with credit issues, but gives you the format and some Georgia rules.

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