rvs494

Replying to Requests for Admissions and Interrogatories

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Tried posting to an old thread with zero replies. I received great advice here before that kept LVNV off my back for a year. Now they're back with a Request for Admissions and interrogatories. This is what I have so far, but there are a few that I'm just at a loss as to how to answer them.

 

REQUEST FOR ADMISSION

 

1. Admit that you applied for and received a credit account on or about 08/07/2002 from Citibank (South Dakota), N.A. ("the Account").

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

2. Admit that you received notice when the Account was sold to the Plaintiff.

Deny

 

3. Admit that you have not filled out any Affidavit of identity theft regarding this Account nor filed any police report regarding any fraudulent activity for this Account.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

4. Admit that the advances and charges made on the Account were made by you or by someone you authorized to make charges on the Account.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

5. Admit that you have received documentation of the Account showing the original account number was xxxxxxxxxxxx7106 (The entire number is on the paper work here.)

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

6. Admit that you received monthly statements of the Account from the original credit issuer showing the advances taken by you, charges to the Account, and payments made by you.

Deny

 

7. Admit that you received copies of the monthly statements attached hereto as Exhibit R1.

Admit. Copies are attached

 

8. Admit that you did not object to the advances, charges and payments so recorded on the monthly statements you received.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

9. Admit that the principal balance past due and owing on the Account is $20,998.77 ("the Account Balance").

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

10. Admit that when applied for the Account, you agreed to pay interest or finance charges on the Account Balance every month.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

11. Admit that you have received written demand by Plaintiff for payment of this Account before commencement of this suit.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

12. Admit that you have not notified Plaintiff either orally or in writing before commencement of this action of any dispute as to the Account and the Account Balance.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

13. Admit that you are not entitled to any credits, off-sets, or deductions.

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

 

14. Admit that there are no documents, writings, letters, records, or papers of any sort which you intend to use as evidence of or a basis for any defense in this action.

Deny

 

INTERROGATORIES

 

1 If your responses to these Requests for Admission are anything other than unequivocal admissions, state what you allege to be facts for each admission denied or not completely admitted.

Statute of limitations

 

2. State your full, correct name and any other name or nickname by which you have ever been known.

Object. Requests materials that should already be in the possession of the plaintiff.

 

3. State your current residence and business addresses.

Object. Requests materials that should already be in the possession of the plaintiff.

 

4. State the name, nature, duration, and place of each employment or occupation which you had during the two years prior to this date.

Objected to on the grounds that it calls for legal conclusion

 

5. State the trade name or assumed name under which you have done business within the past two years and the complete address of each place where business was conducted.

Objected to on the grounds that it calls for legal conclusion

 

6. If you assert that the claim herein is the obligation of anyone other than yourself, state the name and present address of each person and all of the facts which support your position, including your relationship to such other person or persons.

Object. Unduly burdensome, oppressive, and irrelevant.

 

7. State fully, completely, and at length the factual basis for each and every defense which you now assert or will assert into action.

 

8. State the name, occupation, business address and telephone number, and residence address and telephone number of each witness you expect to call at trial of this action, together with a summary of the matters to be testified to by each witness.

 

9. Attach to your answers to these Interrogatories a copy of each and every document, writing, paper or letter which you intend to use as a basis of defense in this action which you expect to offer into evidence upon a trial of this action. If you will not so produce without a Request for Production, then state at length and verbatim the contents of each and every such document, writing, paper, or letter.

 

 

Not sure how to answer 1, 7, 8 and 9. Thought this may have been an old credit card that my ex racked up, but after talking to her, I'm not sure what this is. The copies of credit card statements, which include my name and previous address, say that it's an AT&T Universal Mastercard, and I don't remember even having one of those.

 

Also, none of my credit reports mention Citibank or LVNV Funding. However, there is a mention of Citi on Credit Karma, showing an account opened December of 1998, last updated December 2004, a credit limit of $1,600.00 and a $0 balance.

 

Any insight on how to answer those interrogatories or if I should word something else differently, would be GREATLY appreciated. Thank you all in advance!

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My answers to interrogatories 7, 8 and 9 so far. Would like some insight on any of this.

 

7. Last payment activity as shown in papers provided by Plaintiff, state the date of 5/02/2007, which is outside the Minnesota 6 year Statute of Limitations. Neither Citibank nor LVNV Funding are on any of the Defendant’s credit reports from Experian, Equifax and Trans Union. Plaintiff did not provide an original credit card agreement or any papers containing the Defendant’s signature.

 

8. Object. Unduly burdensome, oppressive, and irrelevant

 

9. Credit reports from all 3 previously mentioned in #7 credit reporting agencies

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http://www.mncourts.gov/?page=3428

http://www.mncourts.gov/?page=511

https://www.revisor.mn.gov/court_rules/rule.php?name=cp-toh

https://www.revisor.mn.gov/court_rules/rule.php?type=cp&id=26#26.02

https://www.revisor.mn.gov/court_rules/rule.php?type=cp&id=26#26.06

https://www.revisor.mn.gov/court_rules/rule.php?type=cp&id=33#33.01

No party may serve more than a total of 50 interrogatories upon any other party unless permitted to do so by the court upon motion, notice and a showing of good cause.Rule 33.Interrogatories to Parties

https://www.revisor.mn.gov/court_rules/rule.php?type=cp&id=34

Rule 34.Production of Documents, Electronically Stored Information The party upon whom the request is served shall serve a written response within 30 days after the service of the request, except that a defendant may serve a response within 45 days after service of the summons and complaint upon that defendant.

36.01Request for Admission

https://www.revisor.mn.gov/court_rules/rule.php?type=cp&id=36

An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless the party states that a reasonable inquiry has been made and that the information known or readily obtainable by the party is insufficient to enable the party to admit or deny.

check your rules for answering admissions

Response: After a diligent search and reasonable inquiry made by the defendant 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.

A denial shall fairly meet the substance of the requested admission

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1. Admit that you applied for and received a credit account on or about 08/07/2002 from Citibank (South Dakota), N.A. ("the Account").

my answers 1-14

Response: After a diligent search and reasonable inquiry made by the defendant 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.

your answer:

Defendant has insufficient information to affirm or deny and leaves it to the plaintiff to provide proof.

This answer would be deemed admitted

reason

"An answering party may not give lack of information or knowledge as a reason for failure to admit or deny"

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Statute of limitations is an affirmative defense pleaded in your answer to plaintiff's petition.

541.05 VARIOUS CASES, SIX YEARS.

Subdivision 1.Six-year limitation.

Except where the Uniform Commercial Code otherwise prescribes, the following actions shall be commenced within six years:(1) upon a contract or other obligation, express or implied, as to which no other limitation is expressly prescribed;

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Tried posting to an old thread with zero replies. I received great advice here before that kept LVNV off my back for a year. Now they're back with a Request for Admissions and interrogatories. This is what I have so far, but there are a few that I'm just at a loss as to how to answer them.

 

REQUEST FOR ADMISSION

 

1. Admit that you applied for and received a credit account on or about 08/07/2002 from Citibank (South Dakota), N.A. ("the Account").

Denied

 

2. Admit that you received notice when the Account was sold to the Plaintiff.

Denied

 

3. Admit that you have not filled out any Affidavit of identity theft regarding this Account nor filed any police report regarding any fraudulent activity for this Account.

Admited

 

4. Admit that the advances and charges made on the Account were made by you or by someone you authorized to make charges on the Account.

Denied

 

5. Admit that you have received documentation of the Account showing the original account number was xxxxxxxxxxxx7106 (The entire number is on the paper work here.)

Denied

 

6. Admit that you received monthly statements of the Account from the original credit issuer showing the advances taken by you, charges to the Account, and payments made by you.

Denied

 

7. Admit that you received copies of the monthly statements attached hereto as Exhibit R1.

Admitted

 

8. Admit that you did not object to the advances, charges and payments so recorded on the monthly statements you received.

Denied

 

9. Admit that the principal balance past due and owing on the Account is $20,998.77 ("the Account Balance").

Calls for speculation on the part of the defendant, plaintiff has not provided an accounting from a zero balance

10. Admit that when applied for the Account, you agreed to pay interest or finance charges on the Account Balance every month.

Denied plaintiff has not provided any contract that was signed by the defendant, Plaontiff needs to provide a contract that states the alleged interest and charges. .

 

11. Admit that you have received written demand by Plaintiff for payment of this Account before commencement of this suit.

Admit or deny this one

 

12. Admit that you have not notified Plaintiff either orally or in writing before commencement of this action of any dispute as to the Account and the Account Balance.

Same as 11

 

13. Admit that you are not entitled to any credits, off-sets, or deductions.

Same as no 9

 

14. Admit that there are no documents, writings, letters, records, or papers of any sort which you intend to use as evidence of or a basis for any defense in this action.

Deny

 

INTERROGATORIES

 

1 If your responses to these Requests for Admission are anything other than unequivocal admissions, state what you allege to be facts for each admission denied or not completely admitted.

Statute of limitations, plaintiff has not proved they own the debt or has standing to even bring a suit in this court,

 

2. State your full, correct name and any other name or nickname by which you have ever been known.

Just state your name

 

3. State your current residence and business addresses.

State your addy

4. State the name, nature, duration, and place of each employment or occupation which you had during the two years prior to this date.

Objection; irrelevant, not likely to lead to the discovery of any evidence that can be used by the plaintiff

 

5. State the trade name or assumed name under which you have done business within the past two years and the complete address of each place where business was conducted.

Same as no 4

 

6. If you assert that the claim herein is the obligation of anyone other than yourself, state the name and present address of each person and all of the facts which support your position, including your relationship to such other person or persons.

None

 

7. State fully, completely, and at length the factual basis for each and every defense which you now assert or will assert into action.

Same as no 1, defendant retains the right to amend these defenses as evidence becomes available

8. State the name, occupation, business address and telephone number, and residence address and telephone number of each witness you expect to call at trial of this action, together with a summary of the matters to be testified to by each witness.

 

9. Attach to your answers to these Interrogatories a copy of each and every document, writing, paper or letter which you intend to use as a basis of defense in this action which you expect to offer into evidence upon a trial of this action. If you will not so produce without a Request for Production, then state at length and verbatim the contents of each and every such document, writing, paper, or letter.

Objection; discovery is the proper method to obtain this sort of request.

 

Not sure how to answer 1, 7, 8 and 9. Thought this may have been an old credit card that my ex racked up, but after talking to her, I'm not sure what this is. The copies of credit card statements, which include my name and previous address, say that it's an AT&T Universal Mastercard, and I don't remember even having one of those. Then you deny deny deny and make them prove it,,,,,,first deal with standing,,,make them show proof that they own this debt,,ask for a bill of sale.

 

Also, none of my credit reports mention Citibank or LVNV Funding. However, there is a mention of Citi on Credit Karma, showing an account opened December of 1998, last updated December 2004, a credit limit of $1,600.00 and a $0 balance.

 

Any insight on how to answer those interrogatories or if I should word something else differently, would be GREATLY appreciated. Thank you all in advance!

 

Question,,,you say they are back after a year,,,,is this the same suit that they have not filed anything on in over a year?  if so you could file a motion to quash these rogs and answers as it has taken the plaintiff longer that the rules of trial procedures allow for these.

 

MN rules of trial procedure can be found here http://www.mncourts.gov/?page=511 scroll down to civil its a pdf doc.

rule 26

(3) Time for Initial Disclosures: In General. A party must make the initial disclosures at or within 60 days after the original due date when an answer is required, unless a different time is set by stipulation or court order, or unless an
objection is made in a proposed discovery plan submitted as part of a civil cover sheet required under Rule 104 of the General Rules of Practice for the District Courts. In ruling on the objection, the court must determine what disclosures, if
any, are to be made and must set the time for disclosure.
 
26.04 Timing and Sequence of Discovery
(a)Timing
. Notwithstanding the provisions of Rules 26.02, 30.01, 31.01(a), 33.01(a), 34.02, 36.01, and 45, parties may not seek discovery
from any source before the parties have conferred and prepared a discovery plan as required by Rule 26.06© except in a proceeding
exempt from initial disclosure under Rule 26.01(a)(2), or when allowed by stipulation or court order.

 

 

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In your answer to the complaint, did you deny having an account with the original creditor?

 

Do the credit card statements show any charges and/or payments made by you? 

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Yes, this is the same one as a year ago. They have not filed with the court and there is no Court File number on anything they sent.

 

I did deny having this account when I answered this complaint. And the credit card statements they provided do have charges from places I have been, there is one payment on there from 5/02/2007, listed as "agency payment"

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@rvs494

 

Yes, this is the same one as a year ago. They have not filed with the court and there is no Court File number on anything they sent.

 

I did deny having this account when I answered this complaint. And the credit card statements they provided do have charges from places I have been, there is one payment on there from 5/02/2007, listed as "agency payment"

 

Has it been a full year, more, less?

 

5.04 Filing; Certificate of Service

Any action that is not filed with the court within one year of
commencement against any party is deemed dismissed with prejudice
against all parties unless the parties within that year sign a stipulation to
extend the filing period.

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I sent my answers to the Complaint and Summons on June 27, 2012 and the Admissions and Interrogatories are dated May 16, 2013. So I guess that makes it less than a year.

 

I am over the 30 days to reply to Admissions and Interrogatories because I was out of town, but received a letter from them on June 24, 2013 stating that, "If you fail to provide those answers in writing within 10 days of the date of this letter, a motion for judgment will be made using the admitted Requests." Not sure of why I have an extra 10 days

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@rvs494

 

According to your rules, the lawsuit commenced (began) when you were served.

 

 
II. COMMENCEMENT OF THE ACTION; SERVICE OF
PROCESS, PLEADINGS, MOTIONS, AND ORDERS
 
 
Rule 3. Commencement of the Action; Service of the Complaint
;
Filing Of The Action
 
3.01 Commencement of the Action
 
A civil action is commenced against each defendant:
 
(a) when the summons is served upon that defendant, or
 
(b) at the date of acknowledgement of service if service is made by
mail, or
 
© when the summons is delivered to the sheriff in the county where
the defendant resides for service; but such delivery shall be ineffectual
unless within 60 days thereafter the summons is actually served on that
defendant or the first publication thereof is made.
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Wish I hadn't misplaced the Summons and Compliant they served me (stupid, I know) but it would have been about 30 days prior to June 27, 2012. So what's my next step? Do I still send a reply to the Admissions and Interrogatories?

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Wish I hadn't misplaced the Summons and Compliant they served me (stupid, I know) but it would have been about 30 days prior to June 27, 2012. So what's my next step? Do I still send a reply to the Admissions and Interrogatories?

 

@rvs494

 

After doing some more research, I've discovered that the one year rule is based upon an amendment that was added in February.  It probably doesn't apply to you.  I apologize.

 

Yes, you must answer the requests.  Here's some suggestions:

 

9. Admit that the principal balance past due and owing on the Account is $20,998.77 ("the Account Balance").

 

I would simply deny.  No explanation.

 

 

 

13. Admit that you are not entitled to any credits, off-sets, or deductions.

 

 

Objection.  Defendant has denied owing the debt which is the subject of Plaintiff's Complaint.  In addition, Plaintiff has not provided a complete accounting of the amount claimed in the Complaint.  Without waiving the foregoing objections, Defendant denies.

 

I simply added to BTO's answer.   What it means is that you've denied the debt, so why would you be entitled to credits, off-sets, or deductions?  Also, since they haven't provided a complete accounting, how have they shown that the amount claimed includes all payments, deductions, etc.?

 

9. Attach to your answers to these Interrogatories a copy of each and every document, writing, paper or letter which you intend to use as a basis of defense in this action which you expect to offer into evidence upon a trial of this action. If you will not so produce without a Request for Production, then state at length and verbatim the contents of each and every such document, writing, paper, or letter.

 

If I'm not mistaken, this request would be based upon a request for production of documents.  Interrogatories only requires written answers.

 

Other than cc statements, what did they provide as evidence?  If nothing else, I might state:

 

None at this time.

 

Take note of the discovery rules provided by BTO.  Unless you've left out some information, it appears the plaintiff hasn't complied with those rules.

 

If it were me, I'd contact a consumer attorney.  In my state, I can contact the bar association and request the name of a consumer attorney from the lawyer referral service.  They'll provide me the name of an attorney in my area.  That attorney will give me a consulation at a reduced fee.  Most, if not all, state bars have a lawyer referral service. 

 

A consultation could provide you with some valuable answers.  For instance, if the plaintiff's didn't comply with court rules (Rules 26 and 26.004), how is this to your advantage?

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Yeah, I just found that the admendment doesn't go into effect until July 1st, darn. Apparently, the practice of waiting over a year after commencement was fairly common and that's why it's being amended.

 

Thank you so much for the imput and will take them all into consideration when typing up my answer.

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@BTO429

 

I guess I'm not understanding how they failed to participate in the discovery process. The MN court rules on civil procedure that you provided a link for contains admendments that went into affect just yesterday. And also unaware of how I would file a motion to dismiss when this lawsuit has not yet been filed with the court. Sorry, I truly am a Newbie.

 

In the meantime, I did type up all my answers and did add a couple of things I found elsewhere on the net. Should I leave it how I have it, or take them out?

 

ADMISSIONS

1. Admit that you applied for and received a credit account on or about 08/07/2002 from Citibank (South Dakota), N.A. ("the Account").

Denied

2. Admit that you received notice when the Account was sold to the Plaintiff.

Denied

3. Admit that you have not filled out any Affidavit of identity theft regarding this Account nor filed any police report regarding any fraudulent activity for this Account.

Admit. This answer is no way intended as an admittance of Defendant's obligation to this alleged amount.

4. Admit that the advances and charges made on the Account were made by you or by someone you authorized to make charges on the Account.

Denied

5. Admit that you have received documentation of the Account showing the original account number was 5491130342057106.

Denied

 

6. Admit that you received monthly statements of the Account from the original credit issuer showing the advances taken by you, charges to the Account, and payments made by you.

Denied

7. Admit that you received copies of the monthly statements attached hereto as Exhibit R1.

Admit. This answer is no way intended as an admittance of Defendant's obligation to this alleged amount.

8. Admit that you did not object to the advances, charges and payments so recorded on the monthly statements you received.

Denied

9. Admit that the principal balance past due and owing on the Account is $20,998.77 ("the Account Balance").

Denied. This answer is no way intended as an admittance of Defendant's obligation to this alleged amount.

10. Admit that when applied for the Account, you agreed to pay interest or finance charges on the Account Balance every month.

Denied.  Plaintiff has not provided any contract that was signed by the Defendant, Plaintiff needs to provide a contract that states the alleged interest and charges.

11. Admit that you have received written demand by Plaintiff for payment of this Account before commencement of this suit.

Admit. This answer is no way intended as an admittance of Defendant's obligation to this alleged amount.

12. Admit that you have not notified Plaintiff either orally or in writing before commencement of this action of any dispute as to the Account and the Account Balance.

Admit. This answer is no way intended as an admittance of Defendant's obligation to this alleged amount.

13. Admit that you are not entitled to any credits, off-sets, or deductions.

Objection.  Defendant has denied owing the debt which is the subject of Plaintiff's Complaint.  In addition, Plaintiff has not provided a complete accounting of the amount claimed in the Complaint.  Without waiving the foregoing objections, Defendant denies.

INTERROGATORIES

1 If your responses to these Requests for Admission are anything other than unequivocal admissions, state what you allege to be facts for each admission denied or not completely admitted.

Statute of limitations, Plaintiff has not proved they own the debt or has standing to even bring a suit in this court.

 

 

2. State your full, correct name and any other name or nickname by which you have ever been known.

My Name

3. State your current residence and business addresses.

Defendant objects in part to Interrogatory No. 3 with regard to the portion asking for business addresses in that it is irrelevant to whether or not he is indebted to Plaintiff. Subject to Defendant's objection, Defendant resides at My Address.

4. State the name, nature, duration, and place of each employment or occupation which you had during the two years prior to this date.

Objection; irrelevant, not likely to lead to the discovery of any evidence that can be used by the Plaintiff

5. State the trade name or assumed name under which you have done business within the past two years and the complete address of each place where business was conducted.

Objection; irrelevant, not likely to lead to the discovery of any evidence that can be used by the Plaintiff

6. If you assert that the claim herein is the obligation of anyone other than yourself, state the name and present address of each person and all of the facts which support your position, including your relationship to such other person or persons.

None

7. State fully, completely, and at length the factual basis for each and every defense which you now assert or will assert into action.

Statute of limitations, Plaintiff has not proved they own the debt or has standing to even bring a suit in this court. Defendant retains the right to amend these defenses as evidence becomes available.

8. State the name, occupation, business address and telephone number, and residence address and telephone number of each witness you expect to call at trial of this action, together with a summary of the matters to be testified to by each witness.

None

9. Attach to your answers to these Interrogatories a copy of each and every document, writing, paper or letter which you intend to use as a basis of defense in this action which you expect to offer into evidence upon a trial of this action. If you will not so produce without a Request for Production, then state at length and verbatim the contents of each and every such document, writing, paper, or letter.

Defendant does not have any such document, and cannot find any such document after a reasonable search, but reserves the right to introduce documents as allowed by law.

 

 

 

Hoping to fax this off sometime this afternoon, just want to make sure that it's ready to go. Thanks to everyone who replied. All great advice.

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Response: After a diligent search and reasonable inquiry made by the defendant 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.
 

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@racecar

 

Are you suggesting that I list that for every answer in the Admissions? Would be response then look like:

 

1. Admit that you applied for and received a credit account on or about 08/07/2002 from Citibank (South Dakota), N.A. ("the Account").

After a diligent search and reasonable inquiry made by the defendant 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.

 

2. Admit that you received notice when the Account was sold to the Plaintiff.

After a diligent search and reasonable inquiry made by the defendant 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.

 

3. Admit that you have not filled out any Affidavit of identity theft regarding this Account nor filed any police report regarding any fraudulent activity for this Account.

After a diligent search and reasonable inquiry made by the defendant 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.

 

Etc....

 

Or would I just put it once as my response for all?

 

And what about number 7, asking for me to admit that Exhibit is attached? Also, BTO suggested that I put denied for number 5, which says that I received documentation of the original account number, and it is on the cc statements that they attached as their Exhibit.

 

Obviously, I haven't faxed this to them yet, I just want to make darn sure that it's ready to go without any of my answers possibly biting me in the butt.

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This is a denial "the answer below" or you can just admit or deny also you can deny or admit in part.

Myself I would answer admissions with this

 

each one is a separate response to the admissions

 

After a diligent search and reasonable inquiry made by the defendant 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.

 

 

For the INTERROGATORIES use BV429 answers

 

You want to answer each question and not help the plaintiff to prove his case. The plaintiff will not help you prove your case either. They just hope you slip up and admit to something.

 

 

 

 

 

 

 

 

 

 

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