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CACH LLC answering interrogatories, request for admissions, request for production

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Would someone be kind enough to help me in answering the following (received after I responded to the summons admitting only to my name and county residence):

 

 

CACH,LLC,
Plaintiff,
vs

Defendant( s).
 
                                                                      PLAINTIFF'S FIRST SET OF INTERROGATORIES

   To:    me, Defendant(s).

Pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, you are to answer the attached interrogatories separately, fully, in writing, and under oath. You should deliver a true copy of your answers to the undersigned attorney within thirty days after the date of service of these interrogatories. To the extent that may be required by the applicable rules of procedure and evidence you are hereby notified that Plaintiff intends to use any and all answers to the attached interrogatories as evidence at trial or any other hearing in this case.

CERTIFICATE OF SERVICE

I CERTIFY that a true and correct copy of the foregoing was furnished by mail…

Law offices of ---
Attorneys dedicated to debt collection

                                                                                          DEFINITIONS

A.    "Issuer" refers to CITIBANK SOUTH DAKOTA, N.A ..

B.    "Account" or "the Account" refers to Account Number ************** with
                 CITIBANK SOUTH DAKOTA, N.A..

C.    "Card" or "the Card" refers to the [Visa, Mastercard, Discover] card that was issued on
                the Account.
 
D.    "Defendant," "you," "your," or "yours" refers to me

E.    "Plaintiff' refers to CACH, LLC and encompasses any person, employee, or other entity
                 authorized to act on Plaintiffs behalf.

F.    "Identify", as used herein with regard to a person, shall mean to provide the following: (1) the person's full name; (2) any other names the person uses or has used in the past; (3) the person's residential address and telephone number; (4) the person's business addressees) and telephone number(s); (5) the person's employer and job title; (6) if the person is a former employee of Defendant, the person's last job title while so employed, and the date of termination; and (7) if the person is not an employee of Defendant but has some other connection with Defendant, for example, agent, independent contractor, officer, director, or customer, the person's connection with Defendant.

G.    "Identify", as used herein with regard to documents or tangible things, shall mean to
describe such documents or tangible things by title, present location, usual location, custodian, and contents.

H.    The word "document" is used herein in its broadest sense to include any medium upon or
with which information is recorded or preserved which belongs to, or is in or subject to the possession, custody or control of Defendant or Defendant's attorneys, agents, employees, trustees, representatives, professional accountants, and any attorneys with whom you may claim the right of joint defense privileges or special relationships, by whomever generated or received, including without limitation: writings; printings; drawings; graphs; charts; notes; typewriting; photographs; slides; motion pictures; videotapes or cassettes; phonograph records; tape or other mechanical recordings; ledgers; books; statements of accounts; journals; notices; letters; catalogs; canceled checks; bank statements; invoices; bills; diaries; purchase orders; memoranda of telephone communications; telegrams; telexes or "TWX's"; telecopies; drafts or preliminary versions of the foregoing; communications to or from any governmental or law enforcement subdivision, officer, or agency; and any other instrument, writing, recording, or data compilation of any nature whatsoever, including any carbon, photographic, microfilm or other type of copy of such items, whether or not such copy is different from the original by reason of any markings, additions, commentaries, revisions, deletions, or substitutions.
 
I.    "Communication" shall include, but is not limited to, any oral communications,
   correspondence, memoranda, reports, records and/or recordings of telephone calls and reports of meetings.

J.    "Person" means an individual, corporation, trust, partnership, incorporated or
   unincorporated association, or any other legal entity.
 
K.    "Credit bureau" means any person who, for compensation, gathers, records, and
   disseminates information relative to the creditworthiness, financial responsibility, paying habits, and other similar information regarding any person, for the purpose of
                furnishing consumer reports to third parties.
 
L.    "Chargeoff date" means April 9, 2012.

M.    "Possession, custody or control" when used in reference to documents or other tangible things includes, without limitation, documents or things in your personal possession,
                 custody or control, documents or things in the possession, custody or control of your attorneys or any other agents of yours, and documents or things    which you could obtain,
                 or copies of which you could obtain by reasonable good faith effort. Possession, custody or control includes constructive possession such that the person need not have
                 actual physical possession. As long as Defendant has a superior right to compel the production from a third party (including an agency, authority or representative), Defendant
                 has possession, custody or control.

N.    "RF A" is Request for Admission.
 
o.    "RFP" is Request for Production.

 

                                                                          INTERROGATORIES AND REQUESTS
Interrogatory No.1:
Identify all persons who participated in the preparation of the answers to these interrogatories.
 
Interrogatory No.2:
If you contend or believe that venue of this action is not proper in the county in which this suit was filed state the factual basis of any such contention or belief.

Interrogatory No. 3:
If Defendant denies having received the Card identify any persons whom Defendant believes may have received the Card.

Interrogatory No.4:
If Defendant denies having used the Card identify any persons whom Defendant believes may have used the Card and state whether each such person was authorized by Defendant to use the Card.
 
Interrogatory No. 5:
If Defendant denies having accepted each advance on the Card, identify each advance or charge on the Card that Defendant disputes.

Interrogatory No.6:
If Defendant has refused to admit RFA No. 14 state the factual basis of any such refusal to admit.

Interrogatory No.7:
If Defendant has refused to admit RFA No. 17 state the balance that Defendant believes to have been due on the Account as of April 9, 2012 and explain how such balance was calculated.

Interrogatory No.8:
If Defendant has refused to admit RF A No. 18 state the date and amount of each payment that Defendant has made on the Account since April 9, 2012.

Interrogatory No.9:
If you have refused to admit RFA No. 22 state the facts on which you base your refusal to admit.

Interrogatory No. 10:
If you have refused to admit RF A No. 23 state the facts on which you base your refusal to admit.

Interrogatory No. 11:
If Defendant contends or believes that the debt that is the subject of this suit is the obligation of any person or entity other than Defendant, identify such other persons or entities and state the facts on which that contention or belief is based.

Interrogatory No. 12:
If you have refused to admit RFA No. 24 state the facts on which you base your refusal to admit.

Interrogatory No. 13:
Identify all persons whom you intend to call as witnesses at trial, other than rebuttal or impeaching witnesses the necessity of whose testimony cannot reasonably be anticipated before trial.

InterrogatoryNo. 14:
Identify all persons whom you may call as expert witnesses at trial and state the subject matter of each such person's anticipated testimony and the opinions of each such person concerning the subject matter of this litigation.

Interrogatory No. 15:
Identify all persons whose mental impressions or opinions have been reviewed by any person whom you may call as an expert witness at trial.

Interrogatory No. 16:
If you are disputing only a portion of the Account please identify which portions of the Account are disputed and which are not and state the reasons for any such disputes.

Interrogatory No. 17:
If you have refused to admit RFA No. 25 then, with regard to each charge comprising the Account which you contend or believe to be unreasonable, state the facts on which you base your refusal to admit.

Interrogatory No. 18:
Please provide the name and address of any and all banking/financial institutions with which you had an account and/or check writing privileges on September 1,2011.

PLAINTIFF'S FIRST REQUESTS FOR ADMISSIONS
 
Pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, you are requested to admit the truth of each of the matters stated below and to admit the genuineness of each of the documents that may be attached as exhibits hereto.
Pursuant to Rule 1.370 the matter is admitted unless the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter within 30 days after service of the request or such shorter or longer time as the court may allow but, unless the court shortens the time, a defendant shall not be required to serve answers or objections before the expiration of 45 days after service of the process and initial pleading upon the defendant.
You are to respond to each of the following requests in writing within the time provided above, by delivering or causing to be delivered to the undersigned attorney a statement admitting or denying specifically, in good faith, each matter of which an admission is requested, or stating in detail the reason{s) you cannot truthfully admit or deny the matter.

DEFINITIONS   A.- O. same

REQUESTS FOR ADMISSIONS
RFANo.l:
You are a resident of the county in which this suit was filed.
RFANo.2:
You signed the original application for the Card in the county in which this suit was filed.
RFA No.3:
You used the Card to make purchases or obtain extensions of credit in the county in which this suit was filed.
RFANo.4:
Defendant applied to Issuer for issuance of the Card.
RFA No.5:
The Card was issued to Defendant.
RFA No.6.
Defendant received the Card.
RFA No.7.
Defendant accepted the Card.
RFANo.8.
Defendant signed the back of the Card.
RFANo.9.
Defendant used the Card to make purchases.
RFANo.10.
Defendant used the Card to obtain extensions of credit.
RFANo.ll:
Issuer made cash advances to Defendant, either as actual cash or in payment for purchases Defendant made from third parties by using the Card.
RFANo.12:
Defendant accepted each such advance on the Account.
RFA No. 13:
By accepting each such advance under the terms of the agreement applicable to the Account Defendant became bound to pay the amounts of such advances, plus any additional charges provided for in such agreement.
RFA No. 14:
Until at least the chargeoff date Issuer sent to Defendant on a monthly basis a statement of charges and balance due on the Account.
RFANo.15:
Defendant did not, within sixty days of the date of any billing statement on the Account send to Issuer a written dispute of the billing statement.
RFA No. 16:
Defendant has failed to repay all of the advances made by Issuer on the Account.
RFA No. 17:
The balance due, owing, and unpaid on the Account, after allowing all just and lawful payments, credits and offsets, was $4900 as of April 9, 2012.
RFA No. 18:
Defendant has made no payments on the Account since April 9, 2012.
RFA No. 19:
At least forty-five days prior to the date on which you were served with the Original Complaint in this case you received a letter from Plaintiff's attorneys requesting payment of the Account.
RFANo.20:
The Account was sold to Plaintiff.
RFA No. 21:
The Account was assigned to Plaintiff.
RFANo.22:
Plaintiff is presently the owner of the Account.
RFANo.23:
Defendant is indebted to Plaintiff for the amounts asserted in Plaintiffs Original Complaint in this case.
RFANo.24:
Defendant is not entitled to any setoff for sums unconnected with payments that have been made by or on behalf of Defendant.
RFA No. 25:
Each of the charges comprising the Account was reasonable.

                                      PLAINTIFF'S FIRST REOUESTS FOR PRODUCTION

 As to each Request for Production set forth below, the requested items are to be produced and delivered to the undersigned attorney at the Law Offices of, , for inspecting, copying or photographing pursuant to Rule 1.350 of the Florida Rules of Civil Procedure. These requests apply to all described documents and tangible things over which Defendant has possession, custody, or control, and production is to be made within thirty days after the date of service of these requests. All original documents produced and identified as such shall be returned to Defendant within thirty days following receipt thereof. In connection with these requests you are instructed that the phrase "possession, custody or control" has the meaning set forth in the Definitions section below.
Privileged Documents: If you withhold any documents based upon a claim of privilege you are to provide a log of such documents, listing them by date, title (or description if untitled), author, and the specific privilege asserted.
Lost, Discarded or Destroyed Documents: If any document requested herein has been lost, discarded, or destroyed, please identify such document by providing the following information in your response:
1.   Description of document.
2.   Date of disposal or loss.
3.   Manner of loss.
4.   Reason for disposal or explanation of loss.
5.   Person authorizing disposal.
6.   Persons having knowledge of disposal or loss.
7.   Person disposing of document.
 
 Authentication and Use at Hearings and Trial: You are hereby notified that all documents produced in response to this request will be used in any pretrial proceeding and at trial.

DEFINITIONS
                                    REQUESTS FOR PRODUCTION
RFP No.1:
If Defendant denies having received the Card please produce all correspondence between Issuer and Defendant.
RFP No.2:
If Defendant denies having received the Card please produce Defendant's checking account records for the period from the account open date through the last payment date, September 1, 2011.
RFP No.3:
Please produce all billing statements from Issuer to Defendant.
RFP No.4:
Please produce true copies all correspondence from Defendant to Issuer disputing any billing statement on the Account, together with proof of sending and receipt of such correspondence.
RFP No.5:
If Defendant has refused to admit RFA No. 16 produce true copies of all payments made on the Account.
RFP No.6:
If you have refused to admit RFA No. 18 produce true copies of all documents on which you base your refusal to admit.
RFP No.7:
If you have refused to admit RFA No. 23 produce true copies of all documents on which you base your refusal to admit.
RFP No.8:
If Defendant contends or believes that the debt that is the subject of this suit is the obligation of any person or entity other than Defendant, please produce the documents on which any such contention or belief is based.
RFP No.9:
If you have refused to admit RFA No. 24 produce true copies of all documents on which you base any assertion of a setoff.

RFP No.lO:
With regard to each expert identified in response to Interrogatory No. l3 please produce:
a.   the expert's resume or curriculum vitae;
b.   all non-privileged notes pertaining to the expert's opinions in this action;
c.   any reports prepared by such expert;
d.   all documents and materials reviewed or relied upon by such expert in preparing the report; and
e.   all correspondence between you or your attorneys and each such expert.

RFP No. 11:
With regard to each person identified in response to Interrogatory No. 14 please produce:
f.   the person's resume or curriculum vitae;
g.   all notes of such person that were reviewed by any expert identified in response to Interrogatory No. 13;
h.   any reports prepared by such person that were reviewed by any expert identified in response to Interrogatory No. 13;
1.   all documents and materials reviewed or relied upon by such person in preparing any such report; and
J.   all correspondence between you or your attorneys and each such expert.
  
RFPNo.12:
Please produce all correspondence between Plaintiff (or any of its attorneys) and Defendant (or any of Defendant's attorneys).

RFP No. 13:
Please produce all correspondence between Issuer and Defendant.

RFP No. 14:
Please produce all statements of Plaintiff or any of its attorneys.

RFP No. 15:
Please produce all witness statements pertaining to this litigation.

RFP No. 16:
If you have refused to admit RF A No. 25 produce true copies of all documents on which you base any assertion of a setoff.

CERTIFICATE OF SERVICE

I CERTIFY that a true and correct copy of the foregoing was furnished by to:
LAW OFFICES OF , Attorneys Dedicated to Debt collection

 

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IN THE DISTRICT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

Banks Name

Plaintiff

Vs.

Defendants Name

Defendant

GENERAL CIVIL DIVISION

CASE NO.: 13-12345-67

DEFENDANTS RESPONSE TO REQUEST FOR ADMISSIONS PROPOUNDED BY PLAINTIFF

My Name hereby responds to the request for admissions propounded by Plaintiff's on September 21, 2013 and states as follows:

No.l:You are a resident of the county in which this suit was filed.
Response: Admit

No.2:You signed the original application for the Card in the county in which this suit was filed.

Response: Denied

No.3:You used the Card to make purchases or obtain extensions of credit in the county in which this suit was filed.
Response: Denied

No.4:Defendant applied to Issuer for issuance of the Card.

Response: Denied

No.5:The Card was issued to Defendant.

Response: Denied

No.6.Defendant received the Card.

Response: Denied

No.7.Defendant accepted the Card.

Response: Denied

No.8.Defendant signed the back of the Card.

Response: Denied

No.9.Defendant used the Card to make purchases.

Response: Denied

No.10.Defendant used the Card to obtain extensions of credit.

Response: Denied

No.ll:Issuer made cash advances to Defendant, either as actual cash or in payment for purchases Defendant made from third parties by using the Card.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No.12:Defendant accepted each such advance on the Account.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No. 13:By accepting each such advance under the terms of the agreement applicable to the Account Defendant became bound to pay the amounts of such advances, plus any additional charges provided for in such agreement.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No. 14:Until at least the chargeoff date Issuer sent to Defendant on a monthly basis a statement of charges and balance due on the Account.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No.15:Defendant did not, within sixty days of the date of any billing statement on the Account send to Issuer a written dispute of the billing statement.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No. 16:Defendant has failed to repay all of the advances made by Issuer on the Account.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No. 17:The balance due, owing, and unpaid on the Account, after allowing all just and lawful payments, credits and offsets, was $4900 as of April 9, 2012.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.


No. 18:Defendant has made no payments on the Account since April 9, 2012.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.



No. 19:At least forty-five days prior to the date on which you were served with the Original Complaint in this case you received a letter from Plaintiff's attorneys requesting payment of the Account.

Response: Denied


No.20:The Account was sold to Plaintiff.

Response: Denied

No. 21:The Account was assigned to Plaintiff.

Response: Denied

No.22:Plaintiff is presently the owner of the Account.

Response: Denied

No.23:Defendant is indebted to Plaintiff for the amounts asserted in Plaintiffs Original Complaint in this case.

Response: Denied

No.24:Defendant is not entitled to any setoff for sums unconnected with payments that have been made by or on behalf of Defendant.

Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.

No. 25:Each of the charges comprising the Account was reasonable.
Response: After a diligent search and a reasonable inquiry was made in an effort to comply with this Request,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.



                                                                          CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been fumished,by Certified U.S. Mail Return Receipt Requested this day of September 21, 2013 to: All counsel of record, see attached mailing list.

Attorneys Name and address Here

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IN THE DISTRICT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

Banks Name

Plaintiff

Vs.

Defendants Name

Defendant

GENERAL CIVIL DIVISION

CASE NO.: 13-12345-67


DEFENDANT’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

COMES NOW, Defendant MY NAME and serves these, responses to Plaintiff's Request for Production of Documents and Notice to Produce as follows:

GENERAL OBJECTIONS
Defendant objects generally to all of Plaintiff’s Requests for Production of Documents and Notice to Produce to Defendant on each of the following grounds:
(a)Defendant reserves the right to supplement or amend these responses and objections as additional information becomes available to Defendant.

REQUESTS FOR PRODUCTION

No.1: If Defendant denies having received the Card please produce all correspondence between Issuer and Defendant.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request.

No.2:If Defendant denies having received the Card please produce Defendant's checking account records for the period from the account open date through the last payment date, September 1, 2011.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request.

No.3:Please produce all billing statements from Issuer to Defendant.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request.

No.4:Please produce true copies all correspondence from Defendant to Issuer disputing any billing statement on the Account, together with proof of sending and receipt of such correspondence.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request.

No.5:If Defendant has refused to admit RFA No. 16 produce true copies of all payments made on the Account.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request.

No.6:If you have refused to admit RFA No. 18 produce true copies of all documents on which you base your refusal to admit.

Response: No documents responsive to this request exist.

No.7:If you have refused to admit RFA No. 23 produce true copies of all documents on which you base your refusal to admit.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.

No.8:If Defendant contends or believes that the debt that is the subject of this suit is the obligation of any person or entity other than Defendant, please produce the documents on which any such contention or belief is based.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.


No.9:If you have refused to admit RFA No. 24 produce true copies of all documents on which you base any assertion of a setoff.

Response: Defendant is not in the possession, custody or control of any documents responsive to this request.  Defendant further states No documents responsive to this request exist.

No.10:With regard to each expert identified in response to Interrogatory No.13 please produce:
a. the expert's resume or curriculum vitae;
Response: None at this time.
b. all non-privileged notes pertaining to the expert's opinions in this action;
Response: None at this time.
c. any reports prepared by such expert;
Response: None at this time.
d. all documents and materials reviewed or relied upon by such expert in preparing the report; and
Response: None at this time.
e. all correspondence between you or your attorneys and each such expert.
Response: None at this time.

No. 11:With regard to each person identified in response to Interrogatory No. 14 please produce:
Response: None at this time.
f. the person's resume or curriculum vitae;

Response: None at this time.

g. all notes of such person that were reviewed by any expert identified in response to Interrogatory No. 13;
Response: None at this time.

h. any reports prepared by such person that were reviewed by any expert identified in response to Interrogatory No. 13;
Response: None at this time.

I. all documents and materials reviewed or relied upon by such person in preparing any such report; and
Response: None at this time.

J. all correspondence between you or your attorneys and each such expert.
Response: None at this time.

No.12:Please produce all correspondence between Plaintiff (or any of its attorneys) and Defendant (or any of Defendant's attorneys).
Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.


No. 13:Please produce all correspondence between Issuer and Defendant.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.


No. 14:Please produce all statements of Plaintiff or any of its attorneys.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.


No. 15:Please produce all witness statements pertaining to this litigation.
Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.


No. 16:If you have refused to admit RF A No. 25 produce true copies of all documents on which you base any assertion of a setoff.

Response: Defendant is not in the possession, custody or control of any documents responsive to this request. Defendant further states No documents responsive to this request exist.

Respectfully submitted this 21st day of September, 2013
 
 

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been fumished,by Certified U.S. Mail Return Receipt Requested this day of September 21, 2013 to: All counsel of record, see attached mailing list.
Attorneys Name and address Here

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IN THE DISTRICT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

Banks Name

Plaintiff

Vs.

Defendants Name

Defendant

GENERAL CIVIL DIVISION

CASE NO.: 13-12345-67

DEFENDANTS RESPONSE TO REQUEST FOR INTERROGATORIES PROPOUNDED BY PLAINTIFF

My Name hereby responds to the request for Interrogatories propounded by Plaintiff's on September 21, 2013 and states as follows:

Interrogatory No.1:
Identify all persons who participated in the preparation of the answers to these interrogatories.
Response: Defendant

Interrogatory No.2:
If you contend or believe that venue of this action is not proper in the county in which this suit was filed state the factual basis of any such contention or belief.
Response: Objection. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence.

Interrogatory No. 3:
If Defendant denies having received the Card identify any persons whom Defendant believes may have received the Card.

Answer: 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 know who received the card as defendant did not mail the card.

Interrogatory No.4:
If Defendant denies having used the Card identify any persons whom Defendant believes may have used the Card and state whether each such person was authorized by Defendant to use the Card.

Answer: 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 know who received the card as defendant did not mail the card. Defendant further states he did not authorize any one to use any card.

Interrogatory No. 5:
If Defendant denies having accepted each advance on the Card, identify each advance or charge on the Card that Defendant disputes.

Answer: The information is not within the answerer's personal knowledge

Interrogatory No.6:
If Defendant has refused to admit RFA No. 14 state the factual basis of any such refusal to admit.

Answer: The information is not within the answerer's personal knowledge

Interrogatory No.7:
If Defendant has refused to admit RFA No. 17 state the balance that Defendant believes to have been due on the Account as of April 9, 2012 and explain how such balance was calculated.

Answer: Defendant cannot identify the information requested as the information requested is not within the answerer's personal knowledge or records.

Interrogatory No.8:
If Defendant has refused to admit RF A No. 18 state the date and amount of each payment that Defendant has made on the Account since April 9, 2012.

Answer: Defendant cannot identify the information requested as the information requested is not within the answerer's personal knowledge or records.

Interrogatory No.9:
If you have refused to admit RFA No. 22 state the facts on which you base your refusal to admit.

Answer: Defendant cannot identify the information requested as the information requested is not within the answerer's personal knowledge or records. Defendant states further this is not my account.

Interrogatory No. 10:
If you have refused to admit RF A No. 23 state the facts on which you base your refusal to admit.
Answer: Defendant cannot identify the information requested as the information requested is not within the answerer's personal knowledge or records. Defendant states further this is not my account.

Interrogatory No. 11:
If Defendant contends or believes that the debt that is the subject of this suit is the obligation of any person or entity other than Defendant, identify such other persons or entities and state the facts on which that contention or belief is based.
Answer: Defendant states the information requested is not within the answerer's personal knowledge or records. Defendant states further this is not my account.

Interrogatory No. 12:
If you have refused to admit RFA No. 24 state the facts on which you base your refusal to admit.

Interrogatory No. 13:
Identify all persons whom you intend to call as witnesses at trial, other than rebuttal or impeaching witnesses the necessity of whose testimony cannot reasonably be anticipated before trial.
Answer: Defendant has no witness.

InterrogatoryNo. 14:
Identify all persons whom you may call as expert witnesses at trial and state the subject matter of each such person's anticipated testimony and the opinions of each such person concerning the subject matter of this litigation.

Answer: Defendant has no expert witness.

Interrogatory No. 15:
Identify all persons whose mental impressions or opinions have been reviewed by any person whom you may call as an expert witness at trial.

Answer: Defendant has no persons whose mental impressions or opinions have been reviewed .

Interrogatory No. 16:
If you are disputing only a portion of the Account please identify which portions of the Account are disputed and which are not and state the reasons for any such disputes.

Answer: The Defendant does not have records which would enable him to respond.


Interrogatory No. 17:
If you have refused to admit RFA No. 25 then, with regard to each charge comprising the Account which you contend or believe to be unreasonable, state the facts on which you base your refusal to admit.

Answer: The Defendant does not have records which would enable him to respond.


Interrogatory No. 18:
Please provide the name and address of any and all banking/financial institutions with which you had an account and/or check writing privileges on September 1,2011.

Answer: Objection. The requested information is not relevant to any issue in this case and not calculated to lead to the discovery of relevant evidence.

 

 

Verification
Before me, the undersigned notary, on this day personally appeared MY NAME, a person whose identity is known to me. After I administered an oath to him, upon his oath, MY NAME said:
My name is MY NAME. I have read the interrogatory responses contained in this document. The facts stated therein are within my personal knowledge and are true and correct to the best of my knowledge.

Respectfully Submitted,

MY Name

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been fumished,by Certified U.S. Mail Return Receipt Requested this day of September 21, 2013 to: All counsel of record, see attached mailing list.

Attorneys Name and address Here

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I just got through with a hearing where the JDB's lawyers objected to my answers for admissions and interrogatories and they were identical to these. The judge agreed with them and ordered me to re-answer both in my 'own words'. I did not feel any bad vibes from the judge about it though. I am re-writing them as we speak and feeling pretty good about it really......

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