joe wilson

Being sued by JDB in kentucky, Need all the help i can get

Recommended Posts

Hay were did everybody GO,

Help,Pretty please 

 

 

Is this any better or should I just stop and get a lawyer??????

 

 

Interrogatories and Requests

Interrogatory

1.         Please state your full name, address, date of birth, place of birth, social security number.

Answer: Objection to SSN request, date of birth, place of birth, on the grounds that it is personal, confidential, and private.  This interrogatory seeks information that is not relevant to any issue in this action, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.  Without waiving objection, defendant will provide name, address and phone number.

 

Interrogatory

2.     What is the name and address of the bank where you have your checking account?   

Answer: 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, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.

 

Interrogatory

3.         Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment

Answer: After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

 

Interrogatory

4.          Identify any payment that you have made to the original creditor, GE Retail Bank/Lowes Consumer, and state the date of the last payment  you made to the original creditor and the amount of that payment.

Answer: After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

 

Interrogatory

5.          Identify any payment that you have made on the account, number xxxxxxxxxxxxxxxxx and state the date of the last payment you made on the Account and the amount of that payment.

Answer: After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory

 

Interrogatory

6.         What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Answer: After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

 

Interrogatory

7.         Please list the date and amount of all payments made by check, money order, banks official check or any other means, that you claim were made on the Account.

Answer: After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

 

Interrogatory

8.           Is the amount that you owe on the Account sued upon correct and, if not, what is the correct amount?

Answer: After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

 

 

 


Interrogatory No. 8

Is the amount that you owe on the Account sued upon correct and, if not, what is the correct amount?

After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

 

Interrogatory No. 9

If any offers of settlement were made to you on your Account, please ste the name, address, and phone number of the person and company who offered you the settlement and how long the settlement was good for?

After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

Interrogatory No. 10

Please state the manner in which you paid any setlement that you allege was made (i.e. check, money order, etc.).

After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

Interrogatory No. 11

Have you ever received a settlement letter or paid in full receipt evidencing an amount you paid toward the Account sued upon?

After a reasonable inquiry, the Defendant has insufficient information to answer this interrogatory.

Interrogatory No. 12

Please provide the following information for each person you will call as a witness at the trial of the captioned matter:
1.  Name, address, and telephone number;

2.  Place of employment;

3.  Relation to the Defendant;

4.  The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Defendant at this time has no witnesses other than for the purpose of impeachment.  Discovery is still ongoing, if there is any evidence brought forward than the Defendant reserves the right to call witnesses for his defense

 

Interrogatory No. 13

Please Identify and describe each exhibit you will use in the trial of the captioned matter.

After a reasonable inquiry and diligent search, Defendant has no documents or exhibits. Discovery is ongoing, and reserves the right to produce any documents or exhibits in the future should plaintiff bring any evidence forward.


Interrogatory No. 14

Are you currently involved in any litigation in which you are a Plaintiff?  If so, then:  1.  in what court is this matter pending?  2.  What is the nature of this claim?

No

Interrogatory No. 15

State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action. 

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

 

Interrogatory No. 16

As to each defense set out in response to Interrogatory Fifteen (15), above, state the following as to notification to Plaintiff by Defendant of such defenses:  (a) the date or dates when notification was given; (  the manner in which notification ws given; and © the specific party or parties to whom notification was given.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

 


 

 

REQUESTS TO ADMIT FACTS

The Plaintiff requests that the Defendant answer the following requests to admit facts pursuant to, and in accordance with Kentucky Rules of Civil Procedure 36.  If the Defendant objects to any requested admission, the reasons therefore shall be stated.  The Defendant's answer shall specifically admit or deny teh requested admission, or set forth in detail the reasons why the Defendant cannont truthfully admit or deny the requested admission.  A denial shall fairly meet the substance of the reawuested admission, and when good faith requires that the Defendant qualify an answer or deny only a part of the matter of which an admission is requested, the Defendant shall specify so much of it is true and qualify or deny teh remainder, again detailing the specificity of the denial or the part thereof.

Fact No. 1

Please admit that you applied to the original creditor, GE Retail Bank/Lowe's Consumer, for the revolving credit card acount, number ##################, in question.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.


Fact No. 2

Please admit that you made charges on the revolving credit card account.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.

 

Fact No.  3

Please admit that by using the revolving credit card account you agreed to its terms and conditions, including but not limited to payment of interest, costs, and attorney's fees.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.

 

 

Fact No. 4

Please admit that you are indebted to the Plaintiff in the amount of $, plus any accrued interest, as shown on Plaintiff's Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven. Therefore without waiving the foregoing objection, defendant denies.

 


Fact No. 5

Please admit that you made payment(s) on your account.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.

Fact No. 6

Please admit that you owe the balance of the Account to the Plaintiff.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven. Therefore without waiving the foregoing objection, defendant denies.

Fact No. 7

Please admit that the correct balance is outlined in the Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven. Therefore without waiving the foregoing objection, defendant denies.

 


Fact No. 8

Please admit that a written agreement existed with the original creditor.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.


DOCUMENTS TO BE PRODUCED

1.  Please provide copies of any and all payments made on the account sued upon, for example, all canceled checks, money order receipts, etc., including a copy of any payment which you allege paid off or settled the account sued upon.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.



2.  Please provide copies of any and all settlement letters or offers to settle regarding the account sued upon.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.



3.  Please provide copies of any and all receipts, letters, or other information that supports your contention that the account was paid in full.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.



4.  Please provide copies of any and all exhibits and/or evidence that you intend to introduce at trial.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.


5.  If you are currently involved in any litigation as a Plaintiff, inside or outside of the state Kentucky, please provide a copy of the petition for damages, including amendments and responses.

None

6.  Please provide copies of all notice letters, collection letters, statements and charge slips in your possession on the contract sued upon.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

Link to post
Share on other sites

or this,

 

 

Interrogatories and Requests

Interrogatory

1.         Please state your full name, address, date of birth, place of birth, social security number.

Answer: Objection to SSN request, date of birth, place of birth, on the grounds that it is personal, confidential, and private.  This interrogatory seeks information that is not relevant to any issue in this action, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.  Without waiving objection, defendant will provide ..........

 

Interrogatory

2.     What is the name and address of the bank where you have your checking account?   

Answer: 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, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.

 

Interrogatory

3.         Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment

Answer:  Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, therefore denied.

 

Interrogatory

4.          Identify any payment that you have made to the original creditor, GE Retail Bank/Lowes Consumer, and state the date of the last payment  you made to the original creditor and the amount of that payment.

 

Answer:  Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, therefore denied.

 

Interrogatory

5.          Identify any payment that you have made on the account, number xxxxxxxxxxxxxxxxx and state the date of the last payment you made on the Account and the amount of that payment.

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.

Interrogatory

6.         What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.

 

Interrogatory

7.         Please list the date and amount of all payments made by check, money order, banks official check or any other means, that you claim were made on the Account.

Answer: Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.

 

 

Interrogatory

8.           Is the amount that you owe on the Account sued upon correct and, if not, what is the correct amount?

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing.

 

 

 



 

Interrogatory No. 9

If any offers of settlement were made to you on your Account, please ste the name, address, and phone number of the person and company who offered you the settlement and how long the settlement was good for?

Defendant objects to the term "your account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.


Interrogatory No. 10

Please state the manner in which you paid any setlement that you allege was made (i.e. check, money order, etc.).

After a reasonable inquiry and diligent search,, the Defendant has insufficient information to answer this interrogatory.

Interrogatory No. 11

Have you ever received a settlement letter or paid in full receipt evidencing an amount you paid toward the Account sued upon?

After a reasonable inquiry and diligent search,, the Defendant has insufficient information to answer this interrogatory.

Interrogatory No. 12

Please provide the following information for each person you will call as a witness at the trial of the captioned matter:
1.  Name, address, and telephone number;

2.  Place of employment;

3.  Relation to the Defendant;

4.  The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Defendant at this time has no witnesses other than for the purpose of impeachment.  Discovery is still ongoing, if there is any evidence brought forward than the Defendant reserves the right to call witnesses for his defense

 

Interrogatory No. 13

Please Identify and describe each exhibit you will use in the trial of the captioned matter.

After a reasonable inquiry and diligent search, Defendant has no documents or exhibits. Discovery is ongoing, and reserves the right to produce any documents or exhibits in the future should plaintiff bring any evidence forward.


Interrogatory No. 14

Are you currently involved in any litigation in which you are a Plaintiff?  If so, then:  1.  in what court is this matter pending?  2.  What is the nature of this claim?

No

Interrogatory No. 15

State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action. 

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

 

Interrogatory No. 16

As to each defense set out in response to Interrogatory Fifteen (15), above, state the following as to notification to Plaintiff by Defendant of such defenses:  (a) the date or dates when notification was given; (  the manner in which notification ws given; and © the specific party or parties to whom notification was given.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

 


 

 

REQUESTS TO ADMIT FACTS

The Plaintiff requests that the Defendant answer the following requests to admit facts pursuant to, and in accordance with Kentucky Rules of Civil Procedure 36.  If the Defendant objects to any requested admission, the reasons therefore shall be stated.  The Defendant's answer shall specifically admit or deny teh requested admission, or set forth in detail the reasons why the Defendant cannont truthfully admit or deny the requested admission.  A denial shall fairly meet the substance of the reawuested admission, and when good faith requires that the Defendant qualify an answer or deny only a part of the matter of which an admission is requested, the Defendant shall specify so much of it is true and qualify or deny teh remainder, again detailing the specificity of the denial or the part thereof.

Fact No. 1

Please admit that you applied to the original creditor, GE Retail Bank/Lowe's Consumer, for the revolving credit card acount, number ##################, in question.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.


Fact No. 2

Please admit that you made charges on the revolving credit card account.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.

 

Fact No.  3

Please admit that by using the revolving credit card account you agreed to its terms and conditions, including but not limited to payment of interest, costs, and attorney's fees.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.

 

 

Fact No. 4

Please admit that you are indebted to the Plaintiff in the amount of $, plus any accrued interest, as shown on Plaintiff's Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven. Therefore without waiving the foregoing objection, defendant denies.

 


Fact No. 5

Please admit that you made payment(s) on your account.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.

Fact No. 6

Please admit that you owe the balance of the Account to the Plaintiff.

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing. Therefore without waiving the foregoing objection, defendant denies.

 

 

 

Fact No. 7

Please admit that the correct balance is outlined in the Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven. Therefore without waiving the foregoing objection, defendant denies.

 


Fact No. 8

Please admit that a written agreement existed with the original creditor.

Answer: Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore without waiving the foregoing objection, defendant denies.


DOCUMENTS TO BE PRODUCED

1.  Please provide copies of any and all payments made on the account sued upon, for example, all canceled checks, money order receipts, etc., including a copy of any payment which you allege paid off or settled the account sued upon.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.



2.  Please provide copies of any and all settlement letters or offers to settle regarding the account sued upon.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.



3.  Please provide copies of any and all receipts, letters, or other information that supports your contention that the account was paid in full.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.



4.  Please provide copies of any and all exhibits and/or evidence that you intend to introduce at trial.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.


5.  If you are currently involved in any litigation as a Plaintiff, inside or outside of the state Kentucky, please provide a copy of the petition for damages, including amendments and responses.

None


6.  Please provide copies of all notice letters, collection letters, statements and charge slips in your possession on the contract sued upon.

After a reasonable inquiry and diligent search,, the Defendant has insufficient information to provide Request.

Link to post
Share on other sites

Quite lengthy.  I am surprised the JDB attorney did not file a MSJ first.  That make me suspicious they may not have the evidence they need to pursue this debt.  In Kentucky it is well established that once the Plaintiffs allege the debt, absent a legitimate material fact in dispute they are entitled to a ruling in their favor.   You may want to study up on your affirmative defenses.   The MTC arbitration is a final attempt to stop the court proceedings.  In Kentucky the Court must review and approve any arbitration ruling before it can be enforced.  You probably should have included some reference to alternative dispute/arbitration in your response to the complaint.  Did you file your own discovery request?

Link to post
Share on other sites

no. I am so lost on this, it seems there are to many things that can mess it up and the deadline is today, so do you think i need to change some things on this last answer

Irregardless you need to get it out today. Do the best you can with what you have and get it out.

Link to post
Share on other sites

Fact No. 1

Please admit that you applied to the original creditor, GE Retail Bank/Lowe's Consumer, for the revolving credit card acount, number ##################, in question.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.


Fact No. 2

Please admit that you made charges on the revolving credit card account.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

 

Fact No.  3

Please admit that by using the revolving credit card account you agreed to its terms and conditions, including but not limited to payment of interest, costs, and attorney's fees.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

 

 

Fact No. 4

Please admit that you are indebted to the Plaintiff in the amount of $, plus any accrued interest, as shown on Plaintiff's Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven.Therefore without waiving the foregoing objection, defendant denies.

 


Fact No. 5

Please admit that you made payment(s) on your account.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

Fact No. 6

Please admit that you owe the balance of the Account to the Plaintiff.

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing. Therefore without waiving the foregoing objection, defendant denies.

 

 

 

Fact No. 7

Please admit that the correct balance is outlined in the Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven.Therefore without waiving the foregoing objection, defendant denies.

 


Fact No. 8

Please admit that a written agreement existed with the original creditor.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.


DOCUMENTS TO BE PRODUCED

1.  Please provide copies of any and all payments made on the account sued upon, for example, all canceled checks, money order receipts, etc., including a copy of any payment which you allege paid off or settled the account sued upon.

After a reasonable inquiry, and diligent search defendant has none of the requested documents in his possession.  Plaintiff should be able to provide requested information from plaintiff's own records.


2.  Please provide copies of any and all settlement letters or offers to settle regarding the account sued upon.

After a reasonable inquiry, and diligent search, defendant has none of the requested items.


3.  Please provide copies of any and all receipts, letters, or other information that supports your contention that the account was paid in full.

Defendant has denied this account, and never contended account was paid, and after a reasonable inquiry, and diligent search defendant has none of the requested information.



4.  Please provide copies of any and all exhibits and/or evidence that you intend to introduce at trial.

After a reasonable inquiry and diligent search defendant has no exhibits at this time.  Defendant will provide any evidence to Plaintiff when and if it becomes available.


5.  If you are currently involved in any litigation as a Plaintiff, inside or outside of the state Kentucky, please provide a copy of the petition for damages, including amendments and responses.

Objection, on the grounds it is personal, private, and confidential, not likely to lead to any discovery.  Without waiving foregoing objection, defendant is not involved in any litigation's.


6.  Please provide copies of all notice letters, collection letters, statements and charge slips in your possession on the contract sued upon.

After a reasonable inquiry and diligent search,, the Defendant has none of the requested information.  Furthermore items should be available to plaintiff from plaintiff's own records.

 
Link to post
Share on other sites
 

Interrogatories and Requests

Interrogatory

1.         Please state your full name, address, date of birth, place of birth, social security number.

Answer: Objection to SSN request, date of birth, place of birth, on the grounds that it is personal, confidential, and private.  This interrogatory seeks information that is not relevant to any issue in this action, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.  Without waiving objection, defendant will provide ..........

 

Interrogatory

2.     What is the name and address of the bank where you have your checking account?   

Answer: 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, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.

 

Interrogatory

3.         Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment

Answer:  Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient, and has no records of any payments.

 

Interrogatory

4.          Identify any payment that you have made to the original creditor, GE Retail Bank/Lowes Consumer, and state the date of the last payment  you made to the original creditor and the amount of that payment.

 

Answer:  Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him and has no records of any payments to GE Retail Bank/Lowes.

Interrogatory

5.          Identify any payment that you have made on the account, number xxxxxxxxxxxxxxxxx and state the date of the last payment you made on the Account and the amount of that payment.

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.

Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him and has no records of any payments to an account number xxxxxxxxxxxxx.

Interrogatory

6.         What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.

 

Interrogatory

7.         Please list the date and amount of all payments made by check, money order, banks official check or any other means, that you claim were made on the Account.

Answer:Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.

 

Interrogatory

8.           Is the amount that you owe on the Account sued upon correct and, if not, what is the correct amount?

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence. Defendant has denied the account. The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing.  After a reasonable inquiry and diligent search defendant does not have the requested information.


 

Interrogatory No. 9

If any offers of settlement were made to you on your Account, please state the name, address, and phone number of the person and company who offered you the settlement and how long the settlement was good for?

Defendant objects to the term "your account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.


Interrogatory No. 10

Please state the manner in which you paid any settlement that you allege was made (i.e. check, money order, etc.).

Defendant has denied this account, and after a reasonable inquiry and diligent search does not have the requested information.


Interrogatory No. 11

Have you ever received a settlement letter or paid in full receipt evidencing an amount you paid toward the Account sued upon?

After a reasonable inquiry and diligent search. defendant does not have the requested information.


Interrogatory No. 12

Please provide the following information for each person you will call as a witness at the trial of the captioned matter:
1.  Name, address, and telephone number;

2.  Place of employment;

3.  Relation to the Defendant;

4.  The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Defendant at this time has no witnesses other than for the purpose of impeachment.  Discovery is still ongoing, if there is any evidence brought forward than the Defendant reserves the right to call witnesses for his defense

 

Interrogatory No. 13

Please Identify and describe each exhibit you will use in the trial of the captioned matter.

After a reasonable inquiry and diligent search, Defendant has no documents or exhibits. Discovery is ongoing, and reserves the right to produce any documents or exhibits in the future should plaintiff bring any evidence forward.


Interrogatory No. 14

Are you currently involved in any litigation in which you are a Plaintiff?  If so, then:  1.  in what court is this matter pending?  2.  What is the nature of this claim?

Objection on the grounds it is personal private and confidential, not likely to lead to any discoverable evidence.  Without waiving foregoing objection, defendant is not involved in any other litigation.

Interrogatory No. 15

State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action. 

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

 

Interrogatory No. 16

As to each defense set out in response to Interrogatory Fifteen (15), above, state the following as to notification to Plaintiff by Defendant of such defenses:  (a) the date or dates when notification was given; (  the manner in which notification ws given; and © the specific party or parties to whom notification was given.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

Link to post
Share on other sites

Fact No. 5

Please admit that you made payment(s) on your account.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

 

 

I'd add that Defendant objects to the term "your account" as it assumes facts not in evidence.

Link to post
Share on other sites

Updated

 

This is what I have so far,

 

 

Fact No. 1

Please admit that you applied to the original creditor, GE Retail Bank/Lowe's Consumer, for the revolving credit card acount, number ##################, in question.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

Fact No. 2

Please admit that you made charges on the revolving credit card account.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

 

Fact No.  3

Please admit that by using the revolving credit card account you agreed to its terms and conditions, including but not limited to payment of interest, costs, and attorney's fees.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

 

 

Fact No. 4

Please admit that you are indebted to the Plaintiff in the amount of $, plus any accrued interest, as shown on Plaintiff's Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven.Therefore without waiving the foregoing objection, defendant denies.

 

Fact No. 5

Please admit that you made payment(s) on your account.

Answer: Defendant objects to the term "Your account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing. Therefore without waiving the foregoing objection, defendant denies.

 

Fact No. 6

Please admit that you owe the balance of the Account to the Plaintiff.

Answer:  Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing. Therefore without waiving the foregoing objection, defendant denies.

 

 

 

Fact No. 7

Please admit that the correct balance is outlined in the Complaint.

Answer: Objection on the grounds that this admission assumes disputed facts and facts not in evidence.  The existence and validity of a contract or that the plaintiff has standing,  have not been proven.Therefore without waiving the foregoing objection, defendant denies.

 

Fact No. 8

Please admit that a written agreement existed with the original creditor.

Answer: Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, Therefore , defendant denies.

DOCUMENTS TO BE PRODUCED

1.  Please provide copies of any and all payments made on the account sued upon, for example, all canceled checks, money order receipts, etc., including a copy of any payment which you allege paid off or settled the account sued upon.

After a reasonable inquiry, and diligent search defendant has none of the requested documents in his possession.  Plaintiff should be able to provide requested information from plaintiff's own records.

2.  Please provide copies of any and all settlement letters or offers to settle regarding the account sued upon.

After a reasonable inquiry, and diligent search, defendant has none of the requested items.

3.  Please provide copies of any and all receipts, letters, or other information that supports your contention that the account was paid in full.

Defendant has denied this account, and never contended account was paid, and after a reasonable inquiry, and diligent search defendant has none of the requested information.


4.  Please provide copies of any and all exhibits and/or evidence that you intend to introduce at trial.

After a reasonable inquiry and diligent search defendant has no exhibits at this time.  Defendant will provide any evidence to Plaintiff when and if it becomes available.

5.  If you are currently involved in any litigation as a Plaintiff, inside or outside of the state Kentucky, please provide a copy of the petition for damages, including amendments and responses.

Objection, on the grounds it is personal, private, and confidential, not likely to lead to any discovery.  Without waiving foregoing objection, defendant is not involved in any litigation's.

6.  Please provide copies of all notice letters, collection letters, statements and charge slips in your possession on the contract sued upon.

After a reasonable inquiry and diligent search,, the Defendant has none of the requested information.  Furthermore items should be available to plaintiff from plaintiff's own records.

 

 

 

Interrogatories and Requests

Interrogatory

1.         Please state your full name, address, date of birth, place of birth, social security number.

Answer: Objection to SSN request, date of birth, place of birth, on the grounds that it is personal, confidential, and private.  This interrogatory seeks information that is not relevant to any issue in this action, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.  Without waiving objection, defendant will provide ..........

 

Interrogatory

2.     What is the name and address of the bank where you have your checking account?   

Answer: 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, and information is not calculated to lead to the discovery of admissible evidence. Information is 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.

 

Interrogatory

3.         Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment

Answer:  Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him is insufficient, and has no records of any payments.

 

Interrogatory

4.          Identify any payment that you have made to the original creditor, GE Retail Bank/Lowes Consumer, and state the date of the last payment  you made to the original creditor and the amount of that payment.

 

Answer:  Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him and has no records of any payments to GE Retail Bank/Lowes.

Interrogatory

5.          Identify any payment that you have made on the account, number xxxxxxxxxxxxxxxxx and state the date of the last payment you made on the Account and the amount of that payment.

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.

Defendant states that after a reasonable inquiry, and diligent search, the information known or readily obtainable by him and has no records of any payments to an account number xxxxxxxxxxxxx.

Interrogatory

6.         What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.

 

Interrogatory

7.         Please list the date and amount of all payments made by check, money order, banks official check or any other means, that you claim were made on the Account.

Answer:Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.

 

Interrogatory

8.           Is the amount that you owe on the Account sued upon correct and, if not, what is the correct amount?

Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence. Defendant has denied the account. The existence and validity of an account has not been proven. Also Defendant has not admitted that a balance is due and owing.  After a reasonable inquiry and diligent search defendant does not have the requested information.

 

Interrogatory No. 9

If any offers of settlement were made to you on your Account, please state the name, address, and phone number of the person and company who offered you the settlement and how long the settlement was good for?

Defendant objects to the term "your account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.

Interrogatory No. 10

Please state the manner in which you paid any settlement that you allege was made (i.e. check, money order, etc.).

Defendant has denied this account, and after a reasonable inquiry and diligent search does not have the requested information.

Interrogatory No. 11

Have you ever received a settlement letter or paid in full receipt evidencing an amount you paid toward the Account sued upon?

After a reasonable inquiry and diligent search. defendant does not have the requested information.

Interrogatory No. 12

Please provide the following information for each person you will call as a witness at the trial of the captioned matter:
1.  Name, address, and telephone number;

2.  Place of employment;

3.  Relation to the Defendant;

4.  The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Defendant at this time has no witnesses other than for the purpose of impeachment.  Discovery is still ongoing, if there is any evidence brought forward than the Defendant reserves the right to call witnesses for his defense

 

Interrogatory No. 13

Please Identify and describe each exhibit you will use in the trial of the captioned matter.

After a reasonable inquiry and diligent search, Defendant has no documents or exhibits. Discovery is ongoing, and reserves the right to produce any documents or exhibits in the future should plaintiff bring any evidence forward.

Interrogatory No. 14

Are you currently involved in any litigation in which you are a Plaintiff?  If so, then:  1.  in what court is this matter pending?  2.  What is the nature of this claim?

Objection on the grounds it is personal private and confidential, not likely to lead to any discoverable evidence.  Without waiving foregoing objection, defendant is not involved in any other litigation.

Interrogatory No. 15

State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action. 

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

 

 

Interrogatory No. 16

As to each defense set out in response to Interrogatory Fifteen (15), above, state the following as to notification to Plaintiff by Defendant of such defenses:  (a) the date or dates when notification was given; (  the manner in which notification ws given; and © the specific party or parties to whom notification was given.

Thus far Plaintiff has not attached any type of contracts or documents as evidence for the defendant to have need of defense. If there is any evidence brought forward than the Defendant reserves the right to defend himself.

Link to post
Share on other sites

The responses look good to me. It is apparent that you have read up on the discovery response. also you might need a meet and confer letter about the objections. I believe you are ok as the court is closed on Saturday and you can use the post office tomorrow morning as you needed the CMRRR for stamped by the post office. Get this out in the morning. They are going to try to get these deemed admitted no matter what but the reasonable inquiry language protects you.

 

Quite frankly, you have basically staunched the blood flow now use the time to study and prepare for trial. The focus for trial is going to be to get the documents and affidavits excluded. Even though it is for CA read ASTmedics and Homeless in California's thread for tactical info

Link to post
Share on other sites
Can i ask for this, also does any one know a good place to find a sample of interrogatories I can sen back to them?
 
 
Kentucky Rules of Civil Procedure (CR) Rule 33.03

Baldwin's Kentucky Revised Statutes Annotated Currentness
Rules of Civil Procedure
superbrowse.gif V Depositions and Discovery
superbrowse.gif CR 33. Interrogatories to Parties
arrow.gifCR 33.03 Option to produce business records
 

Where the answer to an interrogatory may be derived or ascertained from the business records of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, or from a compilation, abstract or summary based thereon, and the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries.
CREDIT(S)

HISTORY: Adopted eff. 10-1-71
 
Rules Civ. Proc., Rule 33.03, KY ST RCP Rule 33.03

Current with amendments received through 03/01/14.

© 2014 Thomson Reuters. No Claim to Orig. US Gov. Works.

END OF DOCUMENT
Link to post
Share on other sites

What is better?

 

Interrogatory

3.         Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment

Answer:  Defendant states that after a reasonable inquiry, the information known or readily obtainable by him is insufficient to enable him to admit or deny this request, . Therefore without waiving the foregoing objection, defendant denies.

 

Interrogatory

3.         Identify any payment that you have made to the Plaintiff and state the date of the last payment you made to the Plaintiff and the amount of that payment

Answer:  Objection on the grounds that this interrogatorie Assumes disputed facts and facts not in evidence.  The existence and validity of the fact that the plaintiff has standing or can prove a transfer of a chain of title have not been proven.

Link to post
Share on other sites

What is better?

 

 

 

Interrogatory

 

6.         What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

Answer:  Defendant objects to the term "the account" to the extent that it assumes disputed facts and facts not in evidence.  The existence and validity of an account has not been proven.  After a diligent search and reasonable inquiry defendant does not have the requested information.

 

 

Interrogatory

 

6.         What was the number of the last check you wrote to the order of the Plaintiff and/or the original creditor as payment on the Account?

AnswerObjection on the grounds that this interrogatorie Assumes disputed facts and facts not in evidence.  The existence and validity of the fact that the plaintiff has standing or can prove a transfer of a chain of title have not been proven.

Link to post
Share on other sites


Does this mean that the plaintiff has to give access to his files????

 

 

 

CR 33.03 Option to produce business records

Baldwin's Kentucky Revised Statutes AnnotatedRules of Civil Procedure





 



Baldwin's Kentucky Revised Statutes Annotated

Rules of Civil Procedure
V Depositions and Discovery
CR 33. Interrogatories to Parties







 


Kentucky Rules of Civil Procedure (CR) Rule 33.03


CR 33.03 Option to produce business records







Where the answer to an interrogatory may be derived or ascertained from the business records of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, or from a compilation, abstract or summary based thereon, and the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries.





Credits


HISTORY: Adopted eff. 10-1-71



 


 


 

Rules Civ. Proc., Rule 33.03, KY ST RCP Rule 33.03

Current with amendments received through 03/01/14.


Link to post
Share on other sites

he send you copies of the records.  That is what the request for documents are for.  Get a list together, and ask for everything, but you have to detail out what your asking for. like if they are suing you for breach of contract, you ask for the contract, if they are asking for account stated, you ask for a complete accounting of the account, if they say they have standing you ask for the bill of sale, and if your name is not on it's face, the purchase agreement for the bill of sale as well as the data sheet. etc.

Link to post
Share on other sites

he send you copies of the records.  That is what the request for documents are for.  Get a list together, and ask for everything, but you have to detail out what your asking for. like if they are suing you for breach of contract, you ask for the contract, if they are asking for account stated, you ask for a complete accounting of the account, if they say they have standing you ask for the bill of sale, and if your name is not on it's face, the purchase agreement for the bill of sale as well as the data sheet. etc.

 Do you now a good place to find samples of the Interrogatories admitts and request for doc's, to send to the plaintiff???

Link to post
Share on other sites

 

Also, I just realized the plaintiff ran my credit report on 7/7/12 is that legal????

 

 

Yes. Most of them will check your credit once a month. Most also subscribe to a program that alerts them to any changes on your credit report. By any changes that can mean something as simple as removing an old address or phone number. 

Link to post
Share on other sites

Ok I am working on my interrogatories to the plaintiff do these look good?????

 

 

 

 

 

 

INTERROGATORIES

 

  1. State the names and addresses of all persons who have knowledge of any

facts relating to the case.

 

  1. Identify all documents that may relate to this action, and attach copies of

such document.

 

  1. Attach a complete copy of any written records or documents that you have

regarding defendant, along with a typed transcription of any handwritten

records and documents.

 

  1. Identify all correspondence between plaintiff and the defendant or its

representatives, and attach copies.

 

  1. If you claim that the defendant made any admissions as to the subject

matter of this lawsuit, state:

  1. the date made;
  2. the name of the person by whom made;
  3. the name and address of the person to whom made;
  4. where made;
  5. the name and address of each person present at the time

            the admission was made;

  1. the contents of the admission; and
  2. if in writing, attach a copy.

 

 

  1. If you or your representative and the defendant have had any oral

communication concerning the subject matter of this lawsuit, state:

  1. the date of the communication;
  2.  the name and address of each participant;
  3. the name and address of each person present at the time of such

communication;  

  1. where such communication took place;
  2.  a summary of what was said by each party participating in the

communication.

 

  1. If you claim that the violation of any statute, rule, regulation or ordinance

is a factor in this litigation, state the exact title and section.

 

  1. Set forth a particular statement of the items of the claim, their amounts

and dates, a calculation in figures of the amount of interest, the payments

or credits, if any, and the net amount due.

 

  1. If the Account was assigned by the Original Creditor, set forth the date and a

description sufficient to identify each Record which reflects or memorializes

each assignment beginning with the Original Creditor and ending with you.

[Note that defense counsel anticipates that you will identify such things as

forward flow agreements, purchase and sale agreements, bills of sale, and

schedules of accounts; in addition, please consult R. 4:10-2(e)(1) concerning

withholding any information.]

 

  1. Attach a copy of each Record identified in your response to Interrogatory #9.

 

  1. With respect to each assignment of the Account, identify the name of each

Natural Person who has personal knowledge as to whether the Account was

described or identified in the assignment.

 

  1. Identify all Records in your possession concerning the Account.

 

  1. Attach a copy of each Record identified in your response to Interrogatory #12.

 

 

  1. Identify each request you sent to either the Original Creditor or assignee of the

Account for either a Record or information about the Account.

 

  1. Attach a copy of each request identified in your response to Interrogatory #14.

 

  1. Attach a complete copy of the response you received for each request identified

in your response to Interrogatory #14.

 

  1. What is the date on which the Account went into default?

 

  1. What is the date of the Account’s last billing statement?

 

 

  1. Explain any difference between the Account’s charge off balance and the balance

on the Account’s last billing statement.

  1. State the name of each Natural Person known to you or to your attorneys who

can demonstrate that each Computer Record is what you claim it to be.

 

  1. State the name of each Natural Person known to you or to your attorneys who is

familiar with the record system used to create and store each Computer Record.

 

  1. State the name of each Natural Person known to you or to your attorneys who

can establish that it was the regular practice of the business which created each

Computer Record to make it.

 

  1. State the name of each Natural Person known to you or to your attorneys who

has personal knowledge that each Business Record was made at or near the time

of observation by a person with actual knowledge or from information supplied

by such a person.

 

  1. State the name of each Natural Person known to you or to your attorneys who

has personal knowledge that each Business Record was made by a business

whose regular practice was make that type or kind of Business Record.

 

  1. State the name of each Natural Person known to you or to your attorneys who

has personal knowledge that each Business Record was in fact made in the

regular course of the business which made it.

 

  1. Attach a copy of each Sworn Statement and indicate in the space below that the

requested item(s) are attached or state the reason why it is not attached.

 

  1. For each Sworn Statement, state whether you have the version which contains

the Declarant’s original signature.

 

  1. Attach a copy of each Record relied on or used by each Declarant in preparing

his or her Sworn Statement and indicate in the space below that the requested

items are attached or state the reason why it is not attached.

 

  1. State the number (or, if unknown, a reasonable estimate of the number) of

affidavits, declarations and certifications made by each Declarant on the same

date as the Declarant’s Sworn Statement.

 

  1. If you assert a claim for legal fees, attach your written retainer agreement with

your attorney and indicate in the space below that the requested item is

attached or state the reason why it is not attached.

 

  1. Attach a copy of Defendant’s application in connection with the Account. If you

do not have possession of that application, state whether you have requested a

copy from anyone.

 

  1. Were there written terms and conditions which governed the Account at the

time the Account was opened?

 

  1. Were the written terms and conditions which governed the Account at the time

the Account was opened changed, modified, amended or replaced at any time

after the Account was opened?

 

  1. If you contend that Defendant’s payment obligations on the Account arose out of

transactions other than transactions in which the money, property, insurance or

services which are the subject of the transactions are primarily for personal,

family or household purposes, then state the factual basis for your contention.

 

  1. Identify and produce a copy of all documents reflecting that the information

described in 15 U.S.C. § 1637(a)(1) through (8) (to the extent applicable) was

disclosed to Defendant before the Account was opened.

 

  1. Identify and produce a copy of all documents which you understand as

constituting written notice of an increase in the Account’s annual percentage

rate in accordance with 15 U.S.C. § 1637(i).

 

  1. Do you have any claims against Defendant other than those arising out of the

Account?

 

  1. Identify each individual you expect to call at trial as an expert witness and

include the subject matter on which each person is expected to testify, the

substance of the facts and opinions to which the expert is expected to testify and

a summary of the grounds for each opinion.

 

  1. What is the full name, job title and work address of the Natural Person who

certified the answers to these interrogatories on your behalf? 

Link to post
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.