DJH715

Answered Petition 2 1/2 years ago - Discovery Request received now

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I was served in Slidell, Louisiana November 2010 with a Petition in Suit on Open Account and served by the court with Precision Recovery Analytics as the Plaintiff.  I had 10 days to answer the petition which I did and filed the petition with the courts a few days after being served.  I also included my defenses to the petition and denied all allegations.  The plaintiff is evidently a Junk Debt agency so I stated I had never heard of them and had no dealings with them.  I also stated in my defenses that I had never entered into any contractual arrangement with them and that the plaintiff provided me with no reliable, credible, or admissible sworn statement or other evidence to the accuracy or validity of the debt.  (I did a DV by certified mail 2 months prior to them filing suit and they sent me nothing). 

 

Periodically since that date I have received from the attorney that filed the suit, standard collection letters trying to collect on the debt (which I have kept).

 

Now today I receive in the mail (NOT by certified mail) a letter from the attorney stating that enclosed is the Plaintiff's First Discovery Request and that I return my responses within the time delays allowed by law.

 

This was not served by the court just regular mail.

 

I assumed this case was over since I hadn't heard anything for almost 3 years now. 

 

My questions are as follows:

 

1.  How long can a case just sit in limbo with the courts with nothing happening?  I answered in November 2010 their questions on the petition and never heard a thing back from the courts.  The clerk's office told me they would send the Plaintiff a copy of my Answer to their suit.

 

2.  Do I need to answer this Discovery?  Or is this a ploy to get my Social Security number, place of employment, etc.

 

3.  In this Discovery they want me to give them copies of any documents received from GE Credit, copies of payment checks, etc.  They should be supplying me with copies.  I stated that in my Defenses in 2010.

 

 

Any help would be deeply appreciated.  I don't want to let this slip by and they receive a Judgment by Default for my failure to reply if necessary.  I want to fight this case.

 

Scratching my head in Louisiana!

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Art. 561.  Abandonment in trial and appellate court

 

A.(1)  An action, except as provided in Subparagraph (2) of this Paragraph, is abandoned when the parties fail to take any step in its prosecution or defense in the trial court for a period of three years, unless it is a succession proceeding.

 

I don't know if that's the correct rule for your court or not.  Check your rules.

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Post what they are asking you and we will help you answer. Then get ready to propound them with your own requests. Looks like the attorney has a calendar, filed so they could toll the sol, and deal with it when they felt like it. Most pro se defendants don't know they can force their hand to stay active on the case by filing motions of their own.

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Art. 561.  Abandonment in trial and appellate court

 

A.(1)  An action, except as provided in Subparagraph (2) of this Paragraph, is abandoned when the parties fail to take any step in its prosecution or defense in the trial court for a period of three years, unless it is a succession proceeding.

 

I don't know if that's the correct rule for your court or not.  Check your rules.

 

Thanks BV you are correct.  I checked my states Civil Procedures and they are filing these Interrogatories just to keep the case alive.  November will make the 3 year mark.

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Post what they are asking you and we will help you answer. Then get ready to propound them with your own requests. Looks like the attorney has a calendar, filed so they could toll the sol, and deal with it when they felt like it. Most pro se defendants don't know they can force their hand to stay active on the case by filing motions of their own.

Yes I want to answer but want to protect myself.  They are basically asking me to prove their case in these questions.  This is a JDB that is suing me and I don't think they can show proof that they purchased the debt from GE Credit.  They have filed the suit under their name and not GE Credit and when I answered the petition almost 3 years ago I stated I had no contract with the JDB and had never heard of them.  I will post the Interrogatories and Document request that they are asking for and hope you can help with the answers.  Then I also would like to send them a First Discovery Request of my own to force them to show documents.  Your help will be greatly appreciated.

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                                                  Plaintiff's First Discovery Request to Defendant

 

Now into Court, through undersigned counsel, comes Plaintiff, Precision Recovery Analytics, Inc., who requests that Defendant respond to the following discovery requests within the time allowed under the Code or Rules of Civil Procedure.  These discovery requests are continuing and Plaintiff requests that Defendant supplement and amend the responses if further information is obtained.

 

Then Definitions are spelled out

 

Interrogatories:

 

1. State your name, address, date of birth, place of employment and Social Security number.  If you object to this interrogatory or any portion of the interrogatory, please state the specific details of your objection, and respond fully to any portion of the interrogatory to which you do not object. (This line is repeated in every question asked so I won't add to each of the following)

 

2. Please state your spouse's name, address, date of birth, place of employment, and social security number.

 

3. Please state whether you opened, or authorized to be opened, the GE Money Bank Walmart Credit Card  account which is the subject of this lawsuit.

 

4. Please state whether you made charges, or authorized any charges to be made on the GE Money Bank Walmart Credit card account, which is the subject of this lawsuit.

 

5. Please identify every payment made to or on the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit.

 

6. If you assert that the balance sued upon is incorrect, state the amount you calculate is due, and state the facts that form the basis of your assertion.  Further, provide your calculations in your response.

 

7. Please identify every bank account utilized by you to pay our personal bills from November 11, 2007 to the date of your response to these discovery requests.

 

8. if you have asserted, or are going to assert any Exceptions, Affirmative Defenses, or basis of dismissal, please state the facts that form the basis of each Exception, Affirmative Defense, or basis of dismissal.

 

9. Please identify any and all communications (as defined above) made by you to GE Money Bank or any other person or entity regarding the Walmart Credit Card account, which is the subject of this lawsuit.

 

10. Please identify any and all communications (as defined above) to you from GE Money Bank or any other person or entity regarding the Walmart Credit Card account, which is the subject of this lawsuit.

 

11. Please identify every dispute you have made on the account, which is the subject of this lawsuit.  Specify the date you became aware of the issue you are disputing, the reason for your dispute, the amount disputed, how you made the dispute, the date which you made the dispute, the outcome of the dispute, and the amount of any credit you claim is due.

 

12. Please identify any and all evidence that you intend to utilize and/or introduce into evidence at trial.

 

13. Please identify and and all witnesses you intend to call at trial or at any hearing in this matter.  Describe the indended testimony for each.

 

Request for Documentation:

 

1. Please produce any and all documentation evidencing the existence of the GE Money Bank Walmard Credit Card account, which is the subject of this lawsuit, including but not limited to the application, terms and conditions, amendments, card member agreements, statements, communications, letters of dispute, privacy notices, credit reports, financial statements, credit applicationis, and any other item that proves or disproves the account's existence and balance due.

 

2. Please produce any and all sales receipts or similar records evidencing charges on and/or credits made to the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit.

 

3. Please produce any and all evidence of payments made to or on the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit, but not limited to, bank statements, bank account registers, cancelled checks, money order receipts, and any other forms of payment or evidence thereof.

 

4. Please produce any evidence demonstrating that the amount you claim is due is correct, and/or that the balance sued upon is correct.

 

5. Please produce a copy of all statements, account registers, and copies of cancelled checks for the bank accounts identified in you answer to Interrogatory #7, with the time frame identified in Interrogatory #7.

 

6. if you have asserted, or are going to assert any Exceptions, Affirmative Defenses or basis of dismissal, please produce any and all documents that form the basis of each Exception, Affirmative Defense, or basis of dismissal.

 

7. Please produce any and all communications (as defined above) made by you to GE Money Bank or any other person or entity regarding the Walmart Credit Card account which is the subject of this lawsuit.

 

8. Please produce any and all communications (as defined above) to you from GE Money Bank or any other person or entity regarding the Walmart Credit Card account, which is the subject of this lawsuit.

 

9. Please produce any and all documents evidencing every dispute you have made on the account, which is the subject of this lawsuit, and that forms the basis of any statement you made in your response to Interrogatory #11.

 

10. Please produce any and all documents you intend to utilize at and/or introduce into evidence at trial.

 

11. Please produce any and all documents which assisted you in answering the Interrogatories in this matter.

 

I have a real problem giving these people my private information especially where I work, date of birth and Social Security # along with my wifes name and private information.  They have not obtained a Judgment yet but want this information.  Do I have to supply this information?

 

Also I find it funny that they are asking for me to tell them and give them proof of any debt with GE Money Bank Walmart Card and that is not who is suing me.  I don't have any of the documentation they are requesting.

 

The only documentation I do have is a copy of two DV letters I sent back in 2010 when I first received a colleciton letter from this company.  They did not respond to my questions of proving the debt back then only stated that the debit was for GE Money Bank Walmart.  No other information or documentation and then I receive a lawsuit right after my DV letter.

 

I would like to know if once they filed suit against me back in 2010 if collection efforts on their part needed to cease.  They have sent me letters trying to collect the debt for the past 2 1/2 years and I have kept these letters.  They have been calling via computer for the past 2 1/2 years also.  Can they do this?

 

I appreciate all the help anyone can give on how to anwser these Interrogatories and Document requests in the proper manner.

 

Do I need to send the answers back by Certified Mail along with my request for Discovery so that I can document that I answered in a timely fashion?

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He said he responded to the dunning by asking for DV and they sent nothing. Is this legal in your state??? Not in mine

I sent first DV letter and all they sent back was GE Money Bank Walmart as the original creditor and the address.  I had asked for validation/proof of this debt and validation of the amount that they said was owed and how they arrived at the balance.  I did not recieve any such proof.  I then wrote another DV letter in response to their letter and requested this proof once again and have received nothing.  Next thing I know I am served with a petition where they filed a lawsuit in November 2010 so I answered their petition and filed that with the courts.  Since then I have periodically received letters every February saying I could settle the account with my tax refund.  They telephone once a week or so also.  Nothing was ever done with the lawsuit until today I received the Discovery/Interrogatories just to keep the suit alive with the courts since the 3 year mark is coming due in November.

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In a DV the only thing they have to give you is the original creditor, and amount. That's it, usually a statement suffices if it is one from the original creditor. I'll help you answer tonight as I am off to work. :)

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Thanks so much Shellih98.  I appreciate your help.

 

I definitly want to make them produce in my Discovery a copy of a document where they purchased the debt from GE Money Bank and how much they paid for that debt along with a breakdown of what is supposedly owed.  I doubt they can produce that but I'm not about to let this company get a Judgment against me and not show proof that I OWE them and not GE Money Bank.

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Working on your responses.  After you answer them, you will propound them with your own discovery requests.  You need to check your rules of civil procedure search out discovery and find out if you have a limit on how many requests you can do.  Some states have a limit, some don't.  If you do have a limit, you will need to be choosy on what you send.

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Limit is 35 questions and document requests.  Thanks so much for your help.

 

November 8th will be 3 years since they filed their suit.  SOL was 9/9/2009 but they filed suit in 2010 to preserve the SOL.  From what I understand this request from them for Discovery is to keep their suit from being abandoned for non activity over the past 3 years.  After I send them my answers and request discovery from them, what happens if they do not answer my request.  If after 30 days they do not respond do I then have to send a letter requesting they cooperate and if still no response do I have to file with the courts a Motion to Compel?  If they don't comply with that motion will I then be able to motion the court to dismiss the case with prejudice?

 

I would like to make sure I know the processes that I will need to do to get this thing thrown out.  I doubt they can produce any documents showing that they own this debt.

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November 8th will be 3 years since they filed their suit.  SOL was 9/9/2009 but they filed suit in 2010 to preserve the SOL.  From what I understand this request from them for Discovery is to keep their suit from being abandoned for non activity over the past 3 years.  After I send them my answers and request discovery from them, what happens if they do not answer my request.  If after 30 days they do not respond do I then have to send a letter requesting they cooperate and if still no response do I have to file with the courts a Motion to Compel?  If they don't comply with that motion will I then be able to motion the court to dismiss the case with prejudice?

 

If they fail to comply with a motion to compel, I don't know if that would be immediate cause for a judge to throw the case out. It would likely get them sanctioned and the judge would not be pleased with them which would work in your favor. 

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Others can check and see if there is a more appropriate response.

 

Interrogatories:

 

1.    State your name, address, date of birth, place of employment and Social Security number.  If you object to this interrogatory or any portion of the interrogatory, please state the specific details of your objection, and respond fully to any portion of the interrogatory to which you do not object. (This line is repeated in every question asked so I won't add to each of the following)

Your Name, Your address. Objection to employment and social security number. On the grounds that it is personal, confidential and private.  This Interrogatory seeks information that is not relevant to any issue in this action, information is not calculated to lead to the discovery of admissible evidence, Information not relevant to any subject matter of this action, and would result in the disclosure of information where such disclosure would violate the privacy rights of the defendant..

 

2.    Please state your spouse's name, address, date of birth, place of employment, and social security number. Objection On the grounds that it is personal, confidential and private.  This Interrogatory seeks information that is not relevant to any issue in this action, information is not calculated to lead to the discovery of admissible evidence, Information not relevant to any subject matter of this action, and would result in the disclosure of information where such disclosure would violate the privacy rights of the defendant..

 

3.    Please state whether you opened, or authorized to be opened, the GE Money Bank Walmart Credit Card  account which is the subject of this lawsuit.

After a reasonable inquiry, the information known or readily obtainable by Defendant is insufficient to enable him to provide a response.

 

 

4.    Please state whether you made charges, or authorized any charges to be made on the GE Money Bank Walmart Credit card account, which is the subject of this lawsuit.

After a reasonable inquiry, the information known or readily obtainable by Defendant is insufficient to enable him to provide a response

 

5.    Please identify every payment made to or on the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit.

Objection on the grounds that it is overly broad, unduly burdensome, cumulative to the extent it seeks documents or records that are not within the current knowledge, possession, custody or control of the defendant.  Plaintiff’s request should be accessible to Plaintiff from plaintiffs own files, from documents or information already in plaintiffs possession. 

 

6.    If you assert that the balance sued upon is incorrect, state the amount you calculate is due, and state the facts that form the basis of your assertion.  Further, provide your calculations in your response.

Objection on the grounds that it is unduly burdensome to the extent it seeks information that is not within the current knowledge possession, custody or control of the defendant.  Additionally, the request is premature as it requests the defendant prior to the completion of discovery to answer if the amount is correct.  The plaintiff should have records of the amount sued upon as being correct from Plaintiff’s own files.  Without waiving the Defendant’s objection, the defendant does not know if the amount on the alleged account he is being sued upon is correct because the defendant has not been provided with any evidence by the plaintiff to prove such amount is correct.

 

7.    Please identify every bank account utilized by you to pay our personal bills from November 11, 2007 to the date of your response to these discovery requests.

Objection On the grounds that it is personal, confidential and private.  This Interrogatory seeks information that is not relevant to any issue in this action, information is not calculated to lead to the discovery of admissible evidence, Information not relevant to any subject matter of this action, and would result in the disclosure of information where such disclosure would violate the privacy rights of the defendant

 

8.    if you have asserted, or are going to assert any Exceptions, Affirmative Defenses, or basis of dismissal, please state the facts that form the basis of each Exception, Affirmative Defense, or basis of dismissal.

Defendant objects to this Interrogatory on the grounds that it is seeking information that is prematurely given that the parties are in the midst of discovery and pertinent documents have not yet been produced by the Plaintiff. Without waiving Defendant’s objection, the Defendant upon completion of discovery with the Plaintiff, will most definitely have further facts based upon her affirmative defenses in this action, and will supply such facts to Plaintiff through discovery. Defendant reserves the right to update this response to this interrogatory at a later date when more information is received

 

 

9.    Please identify any and all communications (as defined above) made by you to GE Money Bank or any other person or entity regarding the Walmart Credit Card account, which is the subject of this lawsuit.

After a reasonable inquiry, the information known or readily obtainable by Defendant is insufficient to enable him to provide a response, Defendant is unaware of communications.

 

 

10.  Please identify any and all communications (as defined above) to you from GE Money Bank or any other person or entity regarding the Walmart Credit Card account, which is the subject of this lawsuit.

After a reasonable inquiry, the information known or readily obtainable by Defendant is insufficient to enable him to provide a response, Defendant is unaware of communications

 

11.  Please identify every dispute you have made on the account, which is the subject of this lawsuit.  Specify the date you became aware of the issue you are disputing, the reason for your dispute, the amount disputed, how you made the dispute, the date which you made the dispute, the outcome of the dispute, and the amount of any credit you claim is due.

Objection, Assumes facts not in evidence.  The existence and validity of the alleged account has not yet been proven, and Defendant has no recollection of the alleged account. Without waiving Objection, The information known or readily obtainable by the Defendant is insufficient to enable a response to this request

 

12.  Please identify any and all evidence that you intend to utilize and/or introduce into evidence at trial.

Defendant objects to this Interrogatory on the grounds that it is seeking information that is prematurely given that the parties are in the midst of discovery and pertinent documents have not yet been produced by the Plaintiff. Without waiving Defendant’s objection, the Defendant upon completion of discovery with the Plaintiff, will most definitely have further facts in this action, and will supply such facts to Plaintiff through discovery. Defendant reserves the right to update this response to this interrogatory at a later date when more information is received

 

 

 

13.  Please identify and and all witnesses you intend to call at trial or at any hearing in this matter.  Describe the intended testimony for each.

Defendant has no witnesses at this time, but reserves the right to call witnesses pending completion of discovery.

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Goodness, Thank you so much Shellie!!!!!!!!

I'm going to type these up tomorrow.

What do I put for the production of documents?

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Request for Documentation:

 

1.    Please produce any and all documentation evidencing the existence of the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit, including but not limited to the application, terms and conditions, amendments, card member agreements, statements, communications, letters of dispute, privacy notices, credit reports, financial statements, credit applications, and any other item that proves or disproves the account's existence and balance due.

Defendant objects as the Plaintiff’s request for documents assumes there is an account being sued upon where no account has been identified as of yet by the Plaintiff or its attorneys.  It is burdensome to the extent it seeks documents or records that are not within the current knowledge, possession, custody or control of the Defendant, more readily or accessible to Plaintiff from Plaintiff’s own files, from documents or information already in Plaintiff’s possession.  Without waiving objection, Defendant cannot provide what is requested, and has no documents in his possession to provide.

 

2.    Please produce any and all sales receipts or similar records evidencing charges on and/or credits made to the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit.

Defendant objects as the Plaintiff’s request for documents assumes there is an account being sued upon where no account has been identified as of yet by the Plaintiff or its attorneys.  It is burdensome to the extent it seeks documents or records that are not within the current knowledge, possession, custody or control of the Defendant, more readily or accessible to Plaintiff from Plaintiff’s own files, from documents or information already in Plaintiff’s possession.  Without waiving objection, Defendant cannot provide what is requested, and has no receipts or similar records in his possession to provide

 

3.    Please produce any and all evidence of payments made to or on the GE Money Bank Walmart Credit Card account, which is the subject of this lawsuit, but not limited to, bank statements, bank account registers, cancelled checks, money order receipts, and any other forms of payment or evidence thereof.

Defendant objects as the Plaintiff’s request for Documents assumes there is an account being sued upon where no account has been identified as of yet by the Plaintiff or its attorneys.  It is burdensome to the extent it seeks documents that are not within the current knowledge possession, custody or control of defendant, or more readily or accessible to Plaintiff from Plaintiff’s own files from documents or information already in Plaintiff’s possession.  Without waiving Objection, after a diligent search defendant is not in possession of any of the requested records.

 

4.    Please produce any evidence demonstrating that the amount you claim is due is correct, and/or that the balance sued upon is correct.

Objection, on the grounds that it assumes there is an account being sued upon where no account has been identified as of yet by plaintiff or its attorneys.  Without waiving objection after a reasonable inquiry, defendant has no knowledge if amount alleged in this suit is correct, and has no records to provide.

 

5.    Please produce a copy of all statements, account registers, and copies of cancelled checks for the bank accounts identified in you answer to Interrogatory #7, with the time frame identified in Interrogatory #7.

Defendant objects as the Plaintiff’s request for documents assumes there is an account being sued upon where no account has been identified as of yet by the Plaintiff or its attorneys.  It is burdensome to the extent it seeks documents or records that are not within the current knowledge, possession, custody or control of the Defendant, more readily or accessible to Plaintiff from Plaintiff’s own files, from documents or information already in Plaintiff’s possession.  Without waiving objection, Defendant cannot provide what is requested, and has no documents in his possession to provide

 

6.    if you have asserted, or are going to assert any Exceptions, Affirmative Defenses or basis of dismissal, please produce any and all documents that form the basis of each Exception, Affirmative Defense, or basis of dismissal.

 

Defendant objects to document request on the grounds that it is seeking information that is prematurely given that the parties are in the midst of discovery and pertinent documents have not yet been produced by the Plaintiff. Without waiving Defendant’s objection, the Defendant upon completion of discovery with the Plaintiff, will most definitely have further facts based upon his affirmative defenses in this action, and will supply such facts to Plaintiff through discovery. Defendant reserves the right to update this response to this request at a later date when more information is received. 

 

 

7.    Please produce any and all communications (as defined above) made by you to GE Money Bank or any other person or entity regarding the Walmart Credit Card account which is the subject of this lawsuit.

Defendant is unaware of and has no documents of any communications to GE Money Bank or other person or entity regarding a Walmart Credit Card Account, and is unable to provide this request.

 

 

8.    Please produce any and all communications (as defined above) to you from GE Money Bank or any other person or entity regarding the Walmart Credit Card account, which is the subject of this lawsuit.

Defendant is unaware of and has no documents of any communications to GE Money Bank or other person or entity regarding a Walmart Credit Card Account, and is unable to provide this request.

 

9.    Please produce any and all documents evidencing every dispute you have made on the account, which is the subject of this lawsuit, and that forms the basis of any statement you made in your response to Interrogatory #11.

Objection, Assumes facts not in evidence.  The existence and validity of the alleged account has not yet been proven, and Defendant has no recollection of the alleged account. Plaintiff’s request for documents assumes there is an account being sued upon where no account has been identified as of yet by the Plaintiff or its attorneys.  It is burdensome to the extent it seeks documents or records that are not within the current knowledge, possession, custody or control of the Defendant, more readily or accessible to Plaintiff from Plaintiff’s own files, from documents or information already in Plaintiff’s possession.  Without waiving objection, Defendant cannot provide what is requested, and has no documents in his possession to provide

 

10.  Please produce any and all documents you intend to utilize at and/or introduce into evidence at trial.

Defendant and Plaintiff are still in the midst of Discovery, and Defendant has yet to send his discovery requests to Plaintiff.  Defendant at this time has no documents to utilize or introduce into evidence, but may have documents at the completion of discovery. Defendant reserves the right to update this document request when and if any documents become available.

 

11.  Please produce any and all documents which assisted you in answering the Interrogatories in this matter.

To answer this request, I would either state you had no assistance, or maybe give them a link to your rules of civil procedure for your state. ;)

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#7 & #8 requests documents to or from any party (not just GE Money) regarding the subject of this lawsuit. I did send a DV letter to this attorney's office on September 7,2010 prior to them filing suit when I first heard of this JDB saying I owed them money. I sent that letter certified mail and received a response from the attorney's office on October 5, 2010 not answering my questions and only saying the original creditor was GE Money. I then sent another DV letter on October 11, 2010 stating that they did not validate the debt by sending me a copies of documents showing that Precision owned this debt.

So do I need to send them those copies since that is correspondence to "any party" regarding the subject of this lawsuit? Are they trying to catch me not telling the truth?

They should have those documents since they were sent to them to validate the debt

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I would next send off a document request.  You may want to reword some of their document requests, and give them their own right back at them.  They wanted you to prove their case, make them prove their own case.  But in addition to those document requests, I would also ask for the bill of sale from original creditor, and each successor ending with the jdb suing you, I would also ask for the complete bill of sale including  any purchase agreement listed in the BOS from the original creditor. (the complete BOS)

ask for statements and account from a zero balance to present balance they are suing you for.

Ask for the contract, and oh heck, I will just post a list of stuff to ask for, pick out as many as you can, but don't go over how much you can ask for.  Post what you put together here before you send it off, so we can help you approve or revise it.

 

You really don't need to send Rogs now, and can serve some of those later if need be.

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And thank you, thank you, thank you. I appreciate all your hard work and can't wait to send this back showing them that I will not fight back.

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And thank you, thank you, thank you. I appreciate all your hard work and can't wait to send this back showing them that I will not fight back.

hopefully you will be showing them you WILL fight back. ;)

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Yes I don't think this JDB that is suing me is the first one this supposed debt was sold to. There may be others before them, so they will need to get a complete chain of sales from Original creditor up until they bought the supposed debt. Is that the Bill of Sale that you are referring to?

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Oh by the way, in the original petition and any correspondence they have sent me they only reference their file number and never have referenced any account number supposedly that I had with GE Money. I don't think they even know a number.

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here are your rules of civil procedure, and rules of evidence.  You need to start studying them, search out parts relating to discovery to start, and read the rules of evidence.  When and if they send you something, read the evidence rules again to see if they are in compliance with them, read about how to file motions, so if you need to file one, you have an idea of how to do it.  You are going to have to study, and fight this until they dismiss or it goes to trial. :)

http://www.legis.state.la.us/lss/toc.htm

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