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Is this how I should do it?

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Is it best to only ask for documents they should have in reference to their complaint or should I list the whole kitchen sink of requests that I've found on the board?


Example: Count 1 in my complaint says

Plaintiff and defendant entered into express or implied contract(s) for services.  Plaintiff has taken assignment of the claims of the additional providers on the attached Exhibit A. (which was just a bogus account summary)

So this is what I want to ask for

Please produce the original contract bearing the Defendant’s signature(s) as alleged in count 1 of the Complaint.
Please produce all documentation or evidence of an offer, assent, mutual consideration, and meeting of the minds such that an agreement was entered into by Defendant.

Please produce proof of assignment showing who the legal owner of alleged contract is

They are asking for $X together with interest, court costs, and atty fees... shouldn't I ask for something that outlines what interest they're talking about?


Count 2 says:

There is presently due and owing, over and above all legal counterclaims the sum of $XXX.XX

Please provide itemized statements from “Account” that demonstrate how the alleged amount of $XXX was calculated; to include the type of services charged to alleged account

Please provide complete payment history showing all credits, debits, and charges posted to the alleged account

Do I need to ask for anything else?


Count 3 says

Defendant(s) has/have breached the agreement(s) with Plaintiff by refusing to make payments due on account.

Copies of ALL correspondence sent to defendant by Plaintiff demonstrating an attempt to collect on the alleged debt, referred to as “Account” in Count 3 of the Complaint

Please produce any notes, memoranda, or likewise, be they handwritten, computerized, or typed, regularly kept in the normal transaction of business of collecting debts, that relate to the Defendant and/or the alleged debt that is the basis of this Complaint.

I feel like something is missing here...


Thanks for your help


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