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Another Cach lawsuit

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I'm being sued by Mandarich Law Group.  I have answered their summons and now have to answer Request for Admissions, Request for production of documents, and Special Interrogatories Set.  For my fist questions, is there a specific form to use put the answers/replies on?  I believe I have the answers obtained from another thread.  


Here are the particulars of the case:



1.    Who is the named plaintiff in the suit?



2. What is the name of the law firm handling the suit?


Mandarich Law Group, LLC 

3. How much are you being sued for?



4. Who is the original creditor?


Bank of America

5. How do you know you are being sued?


Received a summons

6. How were you served? (Mail, In person, Notice on door)


Served in person at my home

7. Was the service legal as required by your state?



8. What was your correspondence (if any) with the people suing you before you think you were being sued?


Originally received calls and letters from several different  CA's.  Never talked to Cach or Mandarich

9. What state and county do you live in?


 CA, prefer not to disclose county if possible

10. When is the last time you paid on this account?


Feb or Mar 2012

11. What is the SOL on the debt?


4 Years

12. What is the status of your case? Suit served? Motions filed?


Answered summons, have received Request for Admissions, Request for production of documents, and Special Interrogatories Set

13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?)



14. Did you request debt validation before the suit was filed?



15. How long do you have to respond to the suit?


Two days to file a response to the above requests


The Causes of Action are:


1.    Breach of Contract

2.    Common counts  (complaint says “Account Stated”)

16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits.


No evidence included


1. Summons

2. Cover sheet

3. Instructions on how to complete cover sheet

4. Complaint

5. Declaration of Venue

6. Notice of Case Assignment



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They should have written the request to you with a few lines for you to add your response to it. If not, and you draft your own; I wouldn't make it any easier on them (or harder on your self), I would just write  the number of the request and then the response to it.


Defendants response to RFA's propunded by plaintiff:






Make sure you send them CMRRR with a proof of service or they will say they never received it.

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Is there a specific form I need to turn in with this, such as a DSC-020 form, or do I just submit it to the clerk?  I assume I need to submit the answers as well as a POS to the clerk.


responses and pos to plaintiff only - not filed with the court/clerk.

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You probably got this, but just in case; by sending them to "plaintiff only": you send them to the lawyer representing plaintiff, at their office (right back where the request came from in the first place).


Also, there is a sample RFPD's in ASTMedics thread that you can send them as well.

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