Quick Question on Admission and ROGS

[scabbo1]

If you object in your admission do you need to respond in the ROG?

 

Question is as follows:

 

 

If your response to Request for Admission 21 was anything but a complete, unqualified admission of said Request for Admission, please state the following:

(a) Each and every reason for your response;

( Describe each and every witness with information supporting or tending to support your response, including the name, address and telephone number of each witness; and

© Describe each and every document in your possession and control supporting or tending to support your response.

 

 

[Flyerfan]

What was admission #21?

[admin]

If you don't have witnesses, say so.  That isn't a big deal.  As far as documents, you can say that all documentation is in the hands of the Plantiff, unless you have some supporting documentation for something like counterclaims.  

[scabbo1]

Here is a more specific instance:

 

 

Admission question

 

 

5. Do you admit that, pursuant to the terms of the XXBANK, credit card, interest applied to any unpaid balances?

RESPONSE: Object. Per terms of the CT Practice Book Plaintiff must provide documents. No “terms” were attached for review. 

 

The ROG for #5 is as follows:

 

 

If your response to Request for Admission #5 was anything but a complete, unqualified admission of said Request for Admission, please state the following:

(a) Each and every reason for your response;

(b Describe each and every witness with information supporting or tending to support your response, including the name, address and telephone number of each witness; and

c. Describe each and every document in your possession and control supporting or tending to support your response.

 

So I've objected in the admit - do I need to respond in the ROG? Would it just be a typical 

 

5. RESPONSE: After conducting a reasonable and good faith inquiry, respondent lacks sufficient personal knowledge to respond.?? 

[Huey Pilot]

Admission #21  

 

Response:  OBJECTION The request is compounded, conditional, and predicated upon speculation and conclusions which are beyond defendant's scope of knowledge therefore must DENY.

 

Defendant has no such witnesses or documents. 

 

Or this works also:

 

RESPONSE: OBJECTION Calls for a legal conclusion based on facts and documents  that have been alleged, but have not been provided to Defendant, of which the purvey is best left to the Trier of Fact. Additionally, Chase is not a party to this action therefore Defendant must Deny.

[Flyerfan]

Here is a more specific instance:

 

 

Admission question

 

 

5. Do you admit that, pursuant to the terms of the XXBANK, credit card, interest applied to any unpaid balances?

RESPONSE: Object. Per terms of the CT Practice Book Plaintiff must provide documents. No “terms” were attached for review. 

 

The ROG for #5 is as follows:

 

 

If your response to Request for Admission #5 was anything but a complete, unqualified admission of said Request for Admission, please state the following:

(a) Each and every reason for your response;

(b Describe each and every witness with information supporting or tending to support your response, including the name, address and telephone number of each witness; and

c. Describe each and every document in your possession and control supporting or tending to support your response.

 

So I've objected in the admit - do I need to respond in the ROG? Would it just be a typical 

 

5. RESPONSE: After conducting a reasonable and good faith inquiry, respondent lacks sufficient personal knowledge to respond.?? 

 

Huey is right. Object to the ROG.

 

In the above example your objection will continue. You have not been given the terms and conditions and, therefore, cannot speculate on them. Also, object that facts are assumed that are not in evidence (that there was an unpaid balance in the first place).

[BV80]

I agree with Huey and Flyer.  Along with what Flyer stated (Also, object that facts are assumed that are not in evidence (that there was an unpaid balance in the first place), if the JDB provided no documentation, that particular admission also calls for you to assume that the account was valid, it was yours, and a debt actually exists.

[BrunoTheJDBkiller]

You don't have to object, you can refer them to the answer in the admission. You can embellish a bit, say that you have stated your reasons in the objection to the admission to the best of your ability considering no documents were provided for review.