Hamachijohn

Need sample Request for Admission to propound on Plaintiff

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I am being sued by Asset Recovery Group in California.

 

I filed the Answer/General Denial.

 

I filed a demand for BOP.  Plaintiff produced response that shows the 1st & last page only for every statement- meaning there was no info about line item charges- only the first and last pages to statements.

 

Plaintiff propounded discovery and I responded.

 

I am now ready to propound discovery on Plaintiffs, and NEED A SAMPLE OF 'REQUEST FOR ADMISSIONS'.

Can anyone help?  I did a search on the forum but did not find any.

 

Here are some RFA that I have so far from doing some research.

 

 

1.Admit that Chase has no direct knowledge of the litigation initiated by Defendant on the account that is in dispute.

2. Admit that no employee or agent of Chase directly requested any employee or agent of Asset Recovery Group to initiate any legal action against Defendant.

3. Admit You do not have the original or a copy of an assignment between You and Chase.

4.  Admit that there is no written agreement between Asset Recovery Group and Defendant.

5. Admit that You did not send the Defendant any notification of assignment of the account or assignment of rights, if any exist.

6. Admit that you are unable to provide a complete accounting for the amount you are claiming.

7.  Admit aht You are engaged in the business of collecting consumer debts and reqularly attempts and collects consumer debts allegedly owed to another and is a "debt collector" as defined by 15 U.S.C. section 1692a(6).

8. Admit that You are barred under the Fair Debt Collection Practices Act, U.S.C. section 1692f(1) from collecting interest on any amount not authorized by the agreement creating the debt or permitted by law.

 

9. Admit that You have not provided defendant with a copy of a contract signed by defendant.
10. Admit that You have not provided defendant with copies of bills of sale establishing its ownership of the account
11. Admit that You have not provided a complete accounting of the amount it is claiming
12. Admit that there were no prior transactions between plaintiff and defendant
13. Admit that You are not a proper party to this action

 

Thank you in advance!

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You should just send them the CCP96, they have to give you everything they intend to use at trial. If it isn't on there, they can't use it. If you do this properly, you won't need any intensive discovery.

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