Discovery responses are too long for pleading paper. HELP PLEASE!!

[Rjr]

Anyone know how I can get my long responses to Request for Admissions fit on at least 2 lines or so?  I have to try to match it up with the corresponding questionnaires number sequence but it keeps going over. Anyone know how to fix this on California Pleading paper?

[Huey Pilot]

Be careful! All you really have to to is Admit, Deny or Object. 

 

You can copy and paste the scanned copy of the Plaintiif's RFA on your new pleading document and take all the space you want to in your answers. Just be sure to DENY everything and only admit your address if it's correct. Plaintiff should already know that. 

 

Here is some sample ideas:

 

Defendant entered into agreement with Chase Bank USA, N.A. for a credit card.

RESPONSE:

DENY - Plaintiffs request for admission no. 1 fails to provide

details of an agreement referenced. No such written agreement has been

appended to the request, therefore defendant must deny.

 

Defendant used Chase Bank USA, N.A.'s credit card account services pursuant to

the credit card agreement ("Agreement") described in Plaintiffs Complaint to

purchase or lease goods or services, obtain cash advances, or transfer balances

from other credit card accounts.

RESPONSE:

DENIED - No such written agreement was appended to

Plaintiffs complaint and none has been appended to the request for admissions,

therefore Defendant must deny. Defendant cannot speculate as to the terms of a

document which has not been provided.

Defendant received one or more copies of the Agreement.

. RESPONSE:

DENIED - Plaintiff has provided no copies of the agreement

referenced and Defendant has no independent recollection of a specific

agreement

 

Pursuant to the Agreement, Defendant promised and agreed to pay to Chase Bank

USA, N.A. its court costs and collection costs in the event of default as permitted

by law.

DENIED - No such written agreement has been appended to

the request, Defendant is unaware of terms of the agreement Plaintiff references

and therefore defendant must DENY.

 

Chase Bank USA, N.A. has performed all of its duties and obligations pursuant to

the Agreement.

RESPONSE

DENIED - The request calls for a legal conclusion as to the

activities of an entity which is not a party to the instant action therefore Defendant

must DENY.

 

Defendant received each and every monthly billing statement described in the

Agreement.

RESPONSE" DENY-Receipt of statements or any other documents connected to th

instant action is a matter for plaintiff to prove at trial. Plaintiff has failed to identify the

"Agreement" it references. Defendant cannot speculate as to the monthly billing statements

pursuant to an unspecified and speculative agreement and therefore denies receipt of any sue i

statements.

 

Defendant did not notify Chase Bank USA, N.A. of any duties or obligations which

Defendant believed Chase Bank USA, N.A. failed to perform pursuant to the

Agreement.

RESPONSE: DENY -"Duties or obligations" are not defined. "Beliefs of the

Defendant" calls for speculation unsupported by admissible evidence and is therefore improper

Defendant has no obligation to inform Chase Bank as to their legal obligations under the law.

The "Agreement" was not appended hereto, therefore defendant cannot respond.

 

If California rules will let you - you can just list the numbers and followed by DENY. You don't need to include their questions. 

 

1. AGREE IN PART DENY IN PART
2. DENY
3. DENY
4. DENY
5. DENY
6. DENY
7. DENY
8. DENY
9. DENY
10. DENY
11. ETC.......

 

HP

[Anon Amos]

If California rules will let you - you can just list the numbers and followed by DENY. You don't need to include their questions.

• AGREE IN PART DENY IN PART
• DENY
• DENY
• DENY
• DENY
• DENY
• DENY
• DENY
• DENY
• DENY
• ETC.......

HP

The CA rules will allow it and it saves you a lot of space. You do not owe them an explanation, just a denial.

[Rjr]

Thank you both! Now I'm stuck with this last one for Request for Admissions. Please help!

 

All conditions precedent to payment of the unpaid principal balance due on your BANK OF AMERICA/FIA CARD SERVICES, N.A., Account Number XXXXXXXXXXXXXX have been performed, waived, satisfied, or extinguished"

[Rjr]

Thank you both! Now I'm stuck with this last one for Request for Admissions. Please help!

 

All conditions precedent to payment of the unpaid principal balance due on your BANK OF AMERICA/FIA CARD SERVICES, N.A., Account Number XXXXXXXXXXXXXX have been performed, waived, satisfied, or extinguished"

 

Any suggestions? Thank you all!

[racecar]

All conditions precedent to payment of the unpaid principal balance due on your BANK OF AMERICA/FIA CARD SERVICES, N.A., Account Number XXXXXXXXXXXXXX have been performed, waived, satisfied, or extinguished"

Response: Objection. The request lacks specificity and is so vague and unclear that the Defendant cannot identify the information requested. Subject to the foregoing: the Defendant does not have any records which would enable him to respond.

or

Response: The information known or readily obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response.

[Rjr]

All conditions precedent to payment of the unpaid principal balance due on your BANK OF AMERICA/FIA CARD SERVICES, N.A., Account Number XXXXXXXXXXXXXX have been performed, waived, satisfied, or extinguished"Response: Objection. The request lacks specificity and is so vague and unclear that the Defendant cannot identify the information requested. Subject to the foregoing: the Defendant does not have any records which would enable him to respond.orResponse: The information known or readily obtainable by the Defendant is insufficient to enable a response to the request. Defendant denies the request until such time as sufficient information is known to make a different response.

Thank you so much! You guys are the best!

For Form Interrogatories number 102.1, it's asking to state your name and any other names you have been known by & your ADDRESS. I've already listed my name & address in the 1st interrogatory but as far as other names, I think it's none of their business what my maiden name is. How can I word this?

Thanks again for your help everyone!

[Rjr]

The CA rules will allow it and it saves you a lot of space. You do not owe them an explanation, just a denial.

I didn't know that I could do this. Thought I had to type out the whole questionnaire again? This info is very helpful thanks so much!!

[Anon Amos]

I didn't know that I could do this. Thought I had to type out the whole questionnaire again? This info is very helpful thanks so much!!

It makes it harder on them if you don't type the question because they will have to dig them up and compare back and forth (at some point you may have to as well, but I would make them work as hard and often as possible). You are required to put the corresponding number (of the RFA or ROG) in front of your response.

As far as them asking for your maiden name (or anything else personal and irrelevant)- OBJECTION: invades privacy, irrelevant, cannot be expected to lead to discoverable information.

[Rjr]

It makes it harder on them if you don't type the question because they will have to dig them up and compare back and forth (at some point you may have to as well, but I would make them work as hard and often as possible). You are required to put the corresponding number (of the RFA or ROG) in front of your response.

As far as them asking for your maiden name (or anything else personal and irrelevant)- OBJECTION: invades of privacy, irrelevant, cannot be expected to lead to discoverable information.

 

Thanks so much Anon Amos. Here I was thinking that I had to match it up to the same sequence on paper. Geez! That's what you get I guess when you're new to this stuff. lol! Thanks again for all your help everyone! Wish me luck!

[debtzapper]

Thank you so much! You guys are the best!   

 

 

 

Yes.  There is a lot of legal talent here, and you were advised by some of the best.

[helpme]

Thank you so much! You guys are the best!

For Form Interrogatories number 102.1, it's asking to state your name and any other names you have been known by & your ADDRESS. I've already listed my name & address in the 1st interrogatory but as far as other names, I think it's none of their business what my maiden name is. How can I word this?

Thanks again for your help everyone!

I have stated my name in the 1st interrogatory, therefore the other names sought is not relevant to the claims at issue in this litigation and is not reasonably calculated to lead to the discovety of admissible evidence.

[Rjr]

I have stated my name in the 1st interrogatory, therefore the other names sought is not relevant to the claims at issue in this litigation and is not reasonably calculated to lead to the discovety of admissible evidence.

 

 Thank you so much!

[Seadragon]

Thank you so much! You guys are the best!

For Form Interrogatories number 102.1, it's asking to state your name and any other names you have been known by & your ADDRESS. I've already listed my name & address in the 1st interrogatory but as far as other names, I think it's none of their business what my maiden name is. How can I word this?

Thanks again for your help everyone!

you can submit an objection and request a protective order. If it is wholly not relevant you will have a fight on your hands, however they do have access to your credit report they will get it from their. Sometimes we fight hard for stuff we really shouldn't and not hard on the things we should. All our names are known and fighting on this stuff in the form interrogatories will piss off the court which feels the form interrogs are "objection proof".

[Rjr]

you can submit an objection and request a protective order. If it is wholly not relevant you will have a fight on your hands, however they do have access to your credit report they will get it from their. Sometimes we fight hard for stuff we really shouldn't and not hard on the things we should. All our names are known and fighting on this stuff in the form interrogatories will piss off the court which feels the form interrogs are "objection prooO

Ok.  I was going to use the response helpme had provided.  Will this still piss off the courts? Sigh, still don't want to give it since the alleged debt occurred when I was already married.

 

Thank you though for the information.  Any information really helps.  I was just telling Anon Amos I had wasted my time typing out the questions in my responses and didn't know that the California Courts allows us to just respond only without retyping the questions. lol.. Thank you all for your help!  Truly appreciate it.

[helpme]

Ok.  I was going to use the response helpme had provided.  Will this still piss off the courts? Sigh, still don't want to give it since the alleged debt occurred when I was already married.

 

Thank you though for the information.  Any information really helps.  I was just telling Anon Amos I had wasted my time typing out the questions in my responses and didn't know that the California Courts allows us to just respond only without retyping the questions. lol.. Thank you all for your help!  Truly appreciate it.

I used this as a strategy to buy some time to research If they don't like your answers they will need to state so in a meet and confer letter giving you anither opportunity. Then if they still don't like your answer they will need to inform you in a meet and confer that they will request a motion to compel. We bought time - back an forth with responses and meet and confers that they missed the window of opportunity to file a motion to compel. So it all depends on what your strategy is.

[Rjr]

Ahh I didn't think of it that way

I used this as a strategy to buy some time to research If they don't like your answers they will need to state so in a meet and confer letter giving you anither opportunity. Then if they still don't like your answer they will need to inform you in a meet and confer that they will request a motion to compel. We bought time - back an forth with responses and meet and confers that they missed the window of opportunity to file a motion to compel. So it all depends on what your strategy is.

Ahh I didn't think of it that way. What's the window for them to file a motion to compel?

Already sent out response to discovery now I want to draft up my own questions and send to them even though I already sent the request for BOP which their deadline is coming up soon!

[BTO429]

Objection, repetitive, the plaintiff has already asked this question