maurodc

Midland Florida HELP needed

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Hello,

 

I was sued by Midland in 2012. 

 

this is the complete history http://www.creditinfocenter.com/community/topic/316286-another-florida-midland-funding-llc-summon/

 

Now after more than a year after I filled Motion to dismiss (never was dismissed) I received "PLAINTIFF'S REQUEST FOR ADIMISSION" AND "INTERROGATORY AND REQUEST FOR PRODUCTION OF DOCUMENT"

 

 

I got this letter a week ago dated July 18

 

Any help would be really appreciated.

 

Mauro

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Hello, this is what I have so far for the request for admission. please let me know if something is wrong. Thanks.

 

1. The defendant opened a credit, store or bank account with the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Defendant does not remember applying for nor using alleged account and therefore denies.

 

2. The defendant borrowed money, took out a loan or received an extension of credit from the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Defendant does not remember applying for nor using alleged account and therefore denies.

 

 3. The defendant financed the sale of an automobile from the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Defendant does not remember applying for nor using alleged account and therefore denies.

4. The defendant received services rendered from the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

5. The defendant knew or should have known that using The Account obligated the Defendant to repay the Plaintiff or its predeccessors-in-interest (if any)

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

6. The defendant made purchases of goods and/or services with money borrowed and withdrawn from The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

7. The defendant received monthly statements sent by Plaintiff or its predeccessors-in-interest (if any) reflecting money borrowed by Defendant and withdrawn from The Account and terms and conditions by which Defendant was to repay such money.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

8. The defendant never objected or protested to the by Plaintiff or its predeccessors-in-interest (if any) in writing regarding any information contained in the monthly statement that Plaintiff or its predeccessors-in-interest (if any) sent the Defendant on The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

9. The defendant never objected or protested to the by Plaintiff or its predeccessors-in-interest (if any) in writing regarding the terms and conditions by which Defendant was obligated to repay the money borrowed and withdrawn from The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

10. The defendant made paments to the Plaintiff or its predeccessors-in-interest (if any) for money borrowed and withdrawn from The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

11. While residing at the address stated in the statements (previously provided to the Defendant), the Defendant received statements from the Plaintiff or its predeccessors-in-interest (if any) reflecting the amount of money borrowed by the Defendant and/or withdrawn from The Account and the payments that the Defendant made toward repaying the amount owed on thThe Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

12. While residing at the address stated in the statements (previously provided to the Defendant), the Defendant received statements from the Plaintiff or its predeccessors-in-interest (if any) reflecting that the Defendant owed the principal amount sought in the Complaint.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

13. The Defendant breached The Account by failing to pay the required monthly payments.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

14. The Defendant did not make any additional payments on The Account after it was charged-off or closed.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

15. The Defendant failed to repay all of the money that the defendant owed on The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

16. The Plaintiff or its predeccessors-in-interest (if any) suffered damages as a result of the Defendant’s failure to repay the amount owed on The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

17. The Defendant is liable for the damages that the Plaintiff or its predeccessors-in-interest (if any) suffered as a result of the Defendant’s failure to repay the amount owed on The Account.

.

Defendant does not remember applying for nor using alleged account and therefore denies

 

18. The Defendant owes the Plaintiff or its predeccessors-in-interest (if any) the principal sum sought in the complaint.

.

Defendant does not remember applying for nor using alleged account and therefore denies

19. The Defendant is indebted to the Plaintiff or its predeccessors-in-interest (if any) on The Account.

.

Defendant does not remember applying for nor using alleged account and therefore denies

 

20. The Documents that the Plaintiff or its predeccessors-in-interest (if any) filed in the subject lawsuit are true and accurate documents on the subject account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

21. ThePlaintiff has standing to file suit on The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

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this is what they told you to do if after 1 year there was nothing. 

FORM 1.989. JUDGMENT DISMISSING FOR

LACK OF PROSECUTION

(a) Judgment When Motion Filed by a Party.

FINAL JUDGMENT OF DISMISSAL

This action was heard on the motion to dismiss for

lack of prosecution of defendant, .................. The

court finds that it does not affirmatively appear from

filing of pleadings, order of court, or otherwise for a

period of 1 year before serving the motion that the

action is being prosecuted, so

IT IS ADJUDGED that this action is dismissed for

lack of prosecution, that plaintiff, ...................., takes

nothing by this action and that defendant,

...................., shall go hence without day.

ORDERED at ...................., Florida, on .....(date)......

Judge

 

 

Quote

 

 

Rule 1420(e)

(e) Failure to Prosecute. All actions in which it

appears on the face of the record that no activity by

filing of pleadings, order of court, or otherwise has

occurred for a period of 1 year shall be dismissed by

the court on its own motion or on the motion of any

interested person, whether a party to the action or

not, after reasonable notice to the parties, unless a

stipulation staying the action is approved by the

court or a stay order has been filed or a party shows

good cause in writing at least 5 days before the

hearing on the motion why the action should remain

pending. Mere inaction for a period of less than 1

year shall not be sufficient cause for dismissal for

failure to prosecute.

 

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I would get back down to the court house and file that. The court does not know they sent you discovery, and it may not even matter since it was over a year. Don't answer the discovery yet, you have 30 days, try the above first. Motion to dismiss for failure to prosecute.

They may revile if the court dismisses, but why make their life easy? Worth a shot. Don't forget to request a hearing on that motion.

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If the MTD does not succeed and you have to answer the interrogatories DO NOT use the same cut and paste answer for every question.  It will simply push the to file a motion to compel answers and diminishes your credibility with the court.

 

Here are some suggestions:

 

10. The defendant made paments to the Plaintiff or its predeccessors-in-interest (if any) for money borrowed and withdrawn from The Account.

 

Denied.  Defendant denies ever making payments on any account to the Plaintiff and no evidence has been presented of any payments to the alleged original creditor.

 

11. While residing at the address stated in the statements (previously provided to the Defendant), the Defendant received statements from the Plaintiff or its predeccessors-in-interest (if any) reflecting the amount of money borrowed by the Defendant and/or withdrawn from The Account and the payments that the Defendant made toward repaying the amount owed on thThe Account.

 

Denied.  Defendant has never received statements from the Plaintiff regarding the account alleged in the complaint documenting credit advanced or payments made.

 

12. While residing at the address stated in the statements (previously provided to the Defendant), the Defendant received statements from the Plaintiff or its predeccessors-in-interest (if any) reflecting that the Defendant owed the principal amount sought in the Complaint.

 

Denied.  Defendant has never received statements from the Plaintiff regarding the account alleged in the complaint documenting credit advanced or payments made.

 

13. The Defendant breached The Account by failing to pay the required monthly payments.

 

Deny

 

14. The Defendant did not make any additional payments on The Account after it was charged-off or closed.

 

Defendant denies making any payments on the account alleged in the complaint.

 

15. The Defendant failed to repay all of the money that the defendant owed on The Account.

 

Deny.

 

16. The Plaintiff or its predeccessors-in-interest (if any) suffered damages as a result of the Defendant’s failure to repay the amount owed on The Account.

 

Denied.  Plaintiff as an alleged predecessor in interest would have purchased the account at a significantly reduced percentage of the alleged principal amount therefore has not suffered damages and is fully aware that accounts may not be accurate or able to be collected in purchasing such a portfolio.

 

17. The Defendant is liable for the damages that the Plaintiff or its predeccessors-in-interest (if any) suffered as a result of the Defendant’s failure to repay the amount owed on The Account.

.

Denied.

 

18. The Defendant owes the Plaintiff or its predeccessors-in-interest (if any) the principal sum sought in the complaint.

.

Denied.  Defendant does not owe the Plaintiff on any account alleged in the complaint.

 

19. The Defendant is indebted to the Plaintiff or its predeccessors-in-interest (if any) on The Account.

.

Denied.

 

20. The Documents that the Plaintiff or its predeccessors-in-interest (if any) filed in the subject lawsuit are true and accurate documents on the subject account.

 

Defendant lacks knowledge or expertise to verify, substantiate or authenticate records that Defendant did not personally produce.

 

21. ThePlaintiff has standing to file suit on The Account.

 

 

Denied.  Plaintiff has not presented a clear chain of title from the Washington Mutual to CHASE to Plaintiff clearly demonstrating a purchase and transfer of title to any account belonging to Defendant.

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Shellie this is what I filled more than a year ago. and never got a response I also included 3 forms with approve or deny options required by the court

 

1.- LACK OF PROSECUTION
Rule 1420(e)
Failure to Prosecute. All actions in which it appears on the face of the record that no activity by filing of pleadings, order of court, or otherwise has occurred for a period of 1 year shall be dismissed by the court on its own motion or on the motion of any interested person, whether a party to the action or not, after reasonable notice to the parties, unless a stipulation staying the action is approved by the court or a stay order has been filed or a party shows good cause in writing at least 5 days before the hearing on the motion why the action should remain pending. Mere inaction for a period of less than 1 year shall not be sufficient cause for dismissal for failure to prosecute.

2.- In the amended Complaint present by the Plaintiff, still fails to provide any contract or agreement due to the age of the debt.

3.- Account Stated.
“Account stated claim involves agreement between persons who have had previous transactions, fixing amount due in respect to such transactions and promising payment.” South Motor Co. of Dade County v. Accountable Const. Co., 707 So.2d 909 (Fla. App. 3 Dist. 1998)

4.-Unjust Enrichment.

A claim for unjust enrichment is an equitable claim, based on a legal fiction created by courts to imply a "contract" as a matter of law
"the circumstances are such that it would be inequitable for the defendant to retain the benefit without paying the value thereof to the plaintiff." Greenfield , 705 So.2d at 931
See Greenfield v. Manor Care, Inc. , 705 So. 2d 926, 930-31 (Fla. Dist. Ct. App. 1997), rev. denied , 717 So. 2d 534 (Fla. 1998).

5.- The Plaintiff has failed to provide any alleged contract, an agreement or any itemized statements or billing of said alleged debts which would constitute intimate knowledge of the creation of the alleged debt. Even if such documents were available, a purchasing/assignee’s plaintiff would be unable to swear to the authenticity of the originating or source documents of a credit transaction because they do not have personal knowledge of the events which transpired at that period of time in the life of the credit agreement. The original cardholder agreement, any correspondence, and monthly statements issued by the original credit grantor are not admissible as the purchasing plaintiff's business records, as the purchasing plaintiff has no personal knowledge of how those records were created or maintained.

RULE 1.130. ATTACHING COPY OF CAUSE OF ACTION AND EXHIBITS
(a) Instruments Attached. All bonds, notes, bills of exchange, contracts, accounts, or documents upon which action may be brought or defense made, or a copy thereof or a copy of the portions thereof material to the pleadings, shall be incorporated in or attached to the pleading. No papers shall be unnecessarily annexed as exhibits. The pleadings shall contain no unnecessary recitals of deeds, documents, contracts, or other instruments.
(B) Part for All Purposes. Any exhibit attached to a pleading shall be considered a part thereof for all purposes. Statements in a pleading may be adopted by reference in a different part of the same pleading, in another pleading, or in any motion.

6. - The Plaintiff has failed to provide A Bill of Sale, that allow the court to identify the accounts that were assigned or sold to the Plaintiff. Neither the Bill of Sale nor the Assignment indicate the account numbers or names of account holders. They do not provide any information that would allow the Court to determine if the alleged account of the Defendant was one of the accounts sold or assigned to the Plaintiff.

See Unifund CCR Partners v Cavender, No, 2007-CC-3040, 14 Fla.L. Weekly Supp. 975b (Orange City. July 20, 2007).

 

7. - The Plaintiff has failed to provide A Bill of Sale between xxx Bank USA NA, and xxxxxx ACQxxxxx CORP.

8.-  According to Fla. Stat. Ann. § 95.011 et seq., the Statue of Limitations on a Debt Collection Oral Contract is four (4) years, the last activity on this account was on xx/2009. Therefore, this is past the Statue of Limitations already.

See PORTFOLIO RECOVERY ASSOCIATES, LLC, Appellant, v_ PAUL FERNANDES, Appellee_ Circuit Court, 15th Judicial Circuit (Appellate) in and for Palm Beach County.
 

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Yes you did but the court never had the hearing, now you can add lack of prosecution to it, make sure there is a hearing scheduled. If it is denied, you might want to file a motion to compel arbitration. If you decide to do that you still need to answer the dogs, and I would answer them with objection, defendant has elected priviate contractual arbitration clause in the contract. I am assuming the account has an arb clause.

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Shellie I added lack of prosecution more than a year ago and they never answer to me.

 

 Do I file the same document again?

 


1.- LACK OF PROSECUTION
Rule 1420(e)
Failure to Prosecute. All actions in which it appears on the face of the record that no activity by filing of pleadings, order of court, or otherwise has occurred for a period of 1 year shall be dismissed by the court on its own motion or on the motion of any interested person, whether a party to the action or not, after reasonable notice to the parties, unless a stipulation staying the action is approved by the court or a stay order has been filed or a party shows good cause in writing at least 5 days before the hearing on the motion why the action should remain pending. Mere inaction for a period of less than 1 year shall not be sufficient cause for dismissal for failure to prosecute.

2.- In the amended Complaint present by the Plaintiff, still fails to provide any contract or agreement due to the age of the debt.

3.- Account Stated.
“Account stated claim involves agreement between persons who have had previous transactions, fixing amount due in respect to such transactions and promising payment.” South Motor Co. of Dade County v. Accountable Const. Co., 707 So.2d 909 (Fla. App. 3 Dist. 1998)

4.-Unjust Enrichment.

A claim for unjust enrichment is an equitable claim, based on a legal fiction created by courts to imply a "contract" as a matter of law
"the circumstances are such that it would be inequitable for the defendant to retain the benefit without paying the value thereof to the plaintiff." Greenfield , 705 So.2d at 931
See Greenfield v. Manor Care, Inc. , 705 So. 2d 926, 930-31 (Fla. Dist. Ct. App. 1997), rev. denied , 717 So. 2d 534 (Fla. 1998).

5.- The Plaintiff has failed to provide any alleged contract, an agreement or any itemized statements or billing of said alleged debts which would constitute intimate knowledge of the creation of the alleged debt. Even if such documents were available, a purchasing/assignee’s plaintiff would be unable to swear to the authenticity of the originating or source documents of a credit transaction because they do not have personal knowledge of the events which transpired at that period of time in the life of the credit agreement. The original cardholder agreement, any correspondence, and monthly statements issued by the original credit grantor are not admissible as the purchasing plaintiff's business records, as the purchasing plaintiff has no personal knowledge of how those records were created or maintained.

RULE 1.130. ATTACHING COPY OF CAUSE OF ACTION AND EXHIBITS
(a) Instruments Attached. All bonds, notes, bills of exchange, contracts, accounts, or documents upon which action may be brought or defense made, or a copy thereof or a copy of the portions thereof material to the pleadings, shall be incorporated in or attached to the pleading. No papers shall be unnecessarily annexed as exhibits. The pleadings shall contain no unnecessary recitals of deeds, documents, contracts, or other instruments.
( B) Part for All Purposes. Any exhibit attached to a pleading shall be considered a part thereof for all purposes. Statements in a pleading may be adopted by reference in a different part of the same pleading, in another pleading, or in any motion.

6. - The Plaintiff has failed to provide A Bill of Sale, that allow the court to identify the accounts that were assigned or sold to the Plaintiff. Neither the Bill of Sale nor the Assignment indicate the account numbers or names of account holders. They do not provide any information that would allow the Court to determine if the alleged account of the Defendant was one of the accounts sold or assigned to the Plaintiff.

See Unifund CCR Partners v Cavender, No, 2007-CC-3040, 14 Fla.L. Weekly Supp. 975b (Orange City. July 20, 2007).

 

7. - The Plaintiff has failed to provide A Bill of Sale between xxx Bank USA NA, and xxxxxx ACQxxxxx CORP.

8.-  According to Fla. Stat. Ann. § 95.011 et seq., the Statue of Limitations on a Debt Collection Oral Contract is four (4) years, the last activity on this account was on xx/2009. Therefore, this is past the Statue of Limitations already.

See PORTFOLIO RECOVERY ASSOCIATES, LLC, Appellant, v_ PAUL FERNANDES, Appellee_ Circuit Court, 15th Judicial Circuit (Appellate) in and for Palm Beach County.
 

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i would do it again, but make sure the court knows it has been 2 years now, insist on a hearing. The jdb's will try to say they just sent you rogs, but I would argue that they have waited to long if that comes up. If your hearing gets scheduled AFTER the rogs would be due, I would ask the court for more time to answer until after the ruling on your motion.

This is the logical thing I see, others may have different ideas.

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Yes, definitely do not use the same answer over and over in your responses.  That will definitely throw up a red flag.  And you might want to send them discovery as well.  Did they ever file their non-resident cost bond?  I bet not.

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Check the docket.  It should show if they filed it.  But they almost never file it unless they get noticed to do it.  They flagrantly disregard that statute.

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Actually that is a Notice to File the Bond, which is what you have to file first.  Basically you are giving them 20 days to file the bond after serving the notice on them.  If they don't file it by then, then you can motion to dismiss for failure to file the bond.  I've had cases dismissed because the JDB didn't file the bond within the 20 days, so I always hold them to it.

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Ok I will do that.

 

 Question: I filed 2 motions to dismiss and never got and answer. This means that I can file this Notice to File a bond without answering "PLAINTIFF'S REQUEST FOR ADIMISSION" AND "INTERROGATORY AND REQUEST FOR PRODUCTION OF DOCUMENT" ?? witch court confirmed is was files Aug-5 ??

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You can file the notice to file cost bond at any point.  It has no bearing on the discovery the plaintiff has sent you.  Keep in mind if you don't answer those requests for admissions within the time frame, then the court will deem all of them admitted.  It is extremely important to answer those first.

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This is what I have so far with the NOTICE TO FILE NON-RESIDENT COST BOND. I want to file this tomorrow and then file NTERROGATORY AND REQUEST FOR PRODUCTION OF DOCUMENT in a couple of days. Please let me know what you think. Thanks in advance.

 

1. The defendant opened a credit, store or bank account with the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Defendant does not remember applying for a credit, store or bank account and therefore denies.

 

2. The defendant borrowed money, took out a loan or received an extension of credit from the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Defendant does not remember applying for nor using alleged account and therefore denies.

 

 3. The defendant financed the sale of an automobile from the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Denied, Defendant does not remember financing the sale of an automobile.

4. The defendant received services rendered from the Plaintiff or its predeccessors-in-interest (if any) on the account that is the subject of the above-styled lawsuit (hereinafter “The Account”).

 

Denied, Defendant does not remember receiving any service from the Plaintiff.

 

5. The defendant knew or should have known that using The Account obligated the Defendant to repay the Plaintiff or its predeccessors-in-interest (if any)

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

6. The defendant made purchases of goods and/or services with money borrowed and withdrawn from The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

7. The defendant received monthly statements sent by Plaintiff or its predeccessors-in-interest (if any) reflecting money borrowed by Defendant and withdrawn from The Account and terms and conditions by which Defendant was to repay such money.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

8. The defendant never objected or protested to the by Plaintiff or its predeccessors-in-interest (if any) in writing regarding any information contained in the monthly statement that Plaintiff or its predeccessors-in-interest (if any) sent the Defendant on The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

9. The defendant never objected or protested to the by Plaintiff or its predeccessors-in-interest (if any) in writing regarding the terms and conditions by which Defendant was obligated to repay the money borrowed and withdrawn from The Account.

 

Defendant does not remember applying for nor using alleged account and therefore denies

 

10. The defendant made payments to the Plaintiff or its predeccessors-in-interest (if any) for money borrowed and withdrawn from The Account.

 

Defendant does not remember making any payments to alleged account and therefore denies

 

11. While residing at the address stated in the statements (previously provided to the Defendant), the Defendant received statements from the Plaintiff or its predeccessors-in-interest (if any) reflecting the amount of money borrowed by the Defendant and/or withdrawn from The Account and the payments that the Defendant made toward repaying the amount owed on The Account.

 

Denied.  Defendant has never received statements from the Plaintiff regarding the account alleged in the complaint documenting credit advanced or payments made.

 

12. While residing at the address stated in the statements (previously provided to the Defendant), the Defendant received statements from the Plaintiff or its predeccessors-in-interest (if any) reflecting that the Defendant owed the principal amount sought in the Complaint.

 

Denied.  Defendant has never received statements from the Plaintiff regarding the account alleged in the complaint documenting credit advanced or payments made.

 

13. The Defendant breached The Account by failing to pay the required monthly payments.

 

Deny.

 

14. The Defendant did not make any additional payments on The Account after it was charged-off or closed.

 

Defendant denies making any payments on the account alleged in the complaint.

 

15. The Defendant failed to repay all of the money that the defendant owed on The Account.

 

Deny.

 

16. The Plaintiff or its predeccessors-in-interest (if any) suffered damages as a result of the Defendant’s failure to repay the amount owed on The Account.

 

Denied.  Plaintiff as an alleged predecessor in interest would have purchased the account at a significantly reduced percentage of the alleged principal amount therefore has not suffered damages and is fully aware that accounts may not be accurate or able to be collected in purchasing such a portfolio.

 

17. The Defendant is liable for the damages that the Plaintiff or its predeccessors-in-interest (if any) suffered as a result of the Defendant’s failure to repay the amount owed on The Account.

Denied.

 

18. The Defendant owes the Plaintiff or its predeccessors-in-interest (if any) the principal sum sought in the complaint.

 

Denied.  Defendant does not owe the Plaintiff on any account alleged in the complaint.

19. The Defendant is indebted to the Plaintiff or its predeccessors-in-interest (if any) on The Account.

 

Denied.

 

20. The Documents that the Plaintiff or its predeccessors-in-interest (if any) filed in the subject lawsuit are true and accurate documents on the subject account.

 

Defendant lacks knowledge or expertise to verify, substantiate or authenticate records that Defendant did not personally produce.

 

21. The Plaintiff has standing to file suit on The Account.

 

Denied.  Plaintiff has not presented a clear chain of title from the Washington Mutual to CHASE to Plaintiff clearly demonstrating a purchase and transfer of title to any account belonging to Defendant.

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Your answers will not work.

File the cost bond.

File the motion to dismiss.

If you answer the discovery now, use the answers @Clydesmom gave you. If you use " you don't remember" they will pretty much say, to bad so sad.

Your rules tell you how to answer, most say something to the effect of. " after a reasonable inquiry, and diligent search, defendant has no ( records, etc) of .......

You can't just say you don't remember.

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You are still using the same answers for most of the questions.  You also might have legitimate objections to some of them.  I was going to post an example of responses to requests for admissions but for some reason I can't attach a pdf or image file to a post now (maybe the board gurus can help with that).  

 

You can PM me and send me an email address and I can email it. These answers are from a JDB answering requests for admissions that were sent to them.  You will notice they object to many of them, but they give fairly detailed answers and it's not always the same objection.  They mix it up between 3 or so.  Even if you object, you still have to answer to the best of your ability.  You can use these as a guide, but don't just copy answers.  You have to make them fit your case and what they are asking.

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You are still using the same answers for most of the questions.  You also might have legitimate objections to some of them.  I was going to post an example of responses to requests for admissions but for some reason I can't attach a pdf or image file to a post now (maybe the board gurus can help with that).  

 

You can PM me and send me an email address and I can email it. These answers are from a JDB answering requests for admissions that were sent to them.  You will notice they object to many of them, but they give fairly detailed answers and it's not always the same objection.  They mix it up between 3 or so.  Even if you object, you still have to answer to the best of your ability.  You can use these as a guide, but don't just copy answers.  You have to make them fit your case and what they are asking.

 

 

@LawKitty

 

You are, as usual, extremely kind and generous with your expertise, and especially, with your time.  Thank you.

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Hello,

 

LawKitty Thanks for the pdf document. 

 

I finally got scheduled for a Hearing for my motion to dismiss for lack of prosecution after 2 years. The hearing is an about 2 months.

 

According to the docket, the request for production of documents and interrogatory was filled the July 20 and is already past due. 

 

Can I request for an extension? or is to late now?

 

Thanks.

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