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Facts of a case -Texas

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Hello, first let me say I have found a lot of good information on this site. I am being sued by Midland LLC in Texas. I have read a lot of information about Midland in different law suits ans well as the law suit filed by AG Greg Abbott against Midland. My question goes to the stated facts of my case. In the law suit the lawyers filing against me stated in the facts "The Defendant opened an account with Chase Bank USA, N.A." That is not a true statement. My account was not opened with Chase is was sold to chase. Now maybe I am splitting hairs, but somewhere I read, and I don't recall where, that a lawyer filing a suit in Texas upon signing the complaint is swearing to first hand knowledge of the facts of the case. 

Using a form I found on this site I sent a modified version of a DV. Request #7 was "You claim that Defendant breached a contract. Produce that contract." 

Of course their response was "Plaintiff objects to this request on the grounds that it is irrelevant and equally available to the Defendant. Subject to objection and without waving the same, discovery and investigations are continuing, and Plaintiff reserves the right to amend or supplement this response as additional information becomes available."

Like I stated their fact is not a fact and secondly how can they main justification (or main fact) be irrelevant. Is this a legitimate argument for this case?


Thanks for any advice.


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