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Can some one help me with my response for Plaintiff's Request for Production of Documents?


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I have my admit, and interrogatories done, but I do not know what to for the request for production of documents.

case is LVNV, suing through an attorney in this state. (Colorado)

 

How do I answer their request to "produce and provide a copy of all bank account statements on which Defendant was an authorized signor during July 17th, 2001 through April 17th, 2011. (10 years worth?)

I don't want to give them my personal bank information.

 

2. Produce and provide copies of all payments which you paid on Chase visa account no. xxxxxxxxxxxx from july 2001 thru april 2011.

 

How should I respond? Also they want statements from same account.

Your help is appreciated

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I have my admit, and interrogatories done, but I do not know what to for the request for production of documents.

case is LVNV, suing through an attorney in this state. (Colorado)

 

How do I answer their request to "produce and provide a copy of all bank account statements on which Defendant was an authorized signor during July 17th, 2001 through April 17th, 2011. (10 years worth?)

I don't want to give them my personal bank information.

 

2. Produce and provide copies of all payments which you paid on Chase visa account no. xxxxxxxxxxxx from july 2001 thru april 2011.

 

How should I respond? Also they want statements from same account.

Your help is appreciated

 

 

 

You could object, but then you'll be getting into an argument you may not be prepared to handle. It can be a legitemate request, but it is also an invasion of privacy. They are attempting to prove that you made payments on the account (duh) thereby agreeing to the amount on the monthly statement. That's a crap argument on their part and is basically meaningless. So what, I made payments, big deal. The easiest way to deal with this is to say you do not have any of the requested records after a diligent search. Unless this is close to the statute of limitations, you'll be okay. Add this....Notwithstanding, defendant admits that he / she did occasionally make payments on the subject account.

 

That may defuse their request.....after all, what other reason could they have for wanting to go through all your personal information? A fishing expedition to see if you are a good prospect to collect from if they get a judgment is the only reason, which is improper unless they have a judgment.

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