rvs494

Second Requests for Admissions and Interrogatories

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Just got a second set of Request for Admissions and Interrogatories in the mail today.

 

Request for Admissions 1-8 are requesting that I admit that I resided at my previous address and received mail at my previous address:

 

1. Admit that in August 2004 you resided at (my preivious address)

 

2. Admit that in August 2004 you received mail at (my preivious address)

 

3-8 states the sames thing with the date changed, August 2005, August 2006, May 2007.

 

9. Admit that between December 2009 and August 2010 you made eight payments to Plaintiff totalling $737.90.

 

10. Admit that the payments referenced in Request Number 9 (above) were made on an account previously owned by Citibank.

 

11. Admit that the payments referenced in Request Numbers 9 and 10 (above) were made on an account with an account number ending in 7106.

 

12. Admit that the Account Statement attatched to the Complaint in this matter as Exhibit A accurately reflects payments made by you on the account referenced in Requests 10 and 11.

 

Interrogatory

 

1. If your response to any of the Requests for Admission above was anything other than an unequivocal admission, state what you allege to be the facts for each Request denied or otherwise not fully admitted.

 

As always, any suggestions I can take into consideration will be greatly appreciated!

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I assume none of these are repeats from request #1?

 

Admit 1-8 assuming the information is correct.

Deny #9, assuming Plaintiff isn't the OC. 

#10 & #11, depends on what information has been provided by the Plaintiff. Can you clearly identify the account in question based on the information they've provided?

#12, again depends on documentation

 

Who's the Plaintiff Citibank? A JDB?

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The first set of Requests can be seen at this thread:

http://www.creditinfocenter.com/community/topic/320851-replying-to-requests-for-admissions-and-interrogatories/

 

The Plaintiff is a JDB LVNV Funding

 

The Exhibits they attached look like legit credit card statements, but I don't remember ever having this credit card. A friend of mine suggested that maybe it's a card that my exwife opened and used under my name.

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The first set of Requests can be seen at this thread:

http://www.creditinfocenter.com/community/topic/320851-replying-to-requests-for-admissions-and-interrogatories/

 

The Plaintiff is a JDB LVNV Funding

 

The Exhibits they attached look like legit credit card statements, but I don't remember ever having this credit card. A friend of mine suggested that maybe it's a card that my exwife opened and used under my name.

Deny deny deny then. Not your account, you have no records of it or making any payments on it. 

 

Also LVNV needs to prove standing.

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So am I also denying my previous address? I know it's there just to get me to admit to something. I'm just trying to think of  how to put this together without them thinking that they've got something on me.

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So am I also denying my previous address? I know it's there just to get me to admit to something. I'm just trying to think of  how to put this together without them thinking that they've got something on me.

 

I wouldn't deny those, assuming they are true. It's likely not hard for them to prove it. I assume they're putting those in to show that you used the card and received the bills.

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