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Requests for Admission on Summons and Complaint

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I read through “Answering a complaint correctly” but I need help answering these other requests for admission from CACH, LLC.  Any help would be appreciated.

4. Please admit you used the account to accrue a balance of $xxxx.xx

5. Please admit you agreed to pay the original creditor an its successors and assigns all outstanding balances owed on the account.

6. Please admit you never disputed, with any person or entity, including the original creditor, the outstanding balance of $xxxx.xx on the account

7. Please admit you have not paid the outstanding balance on the account in the sum of not less than $xxxx.xx

8. Please admit you owe the Plaintiff the amount prayed for in the Complaint

9. Please admit you have no facts which would contradict the amounts owed to Plaintiff

10. Please admit YOU have no facts to support your affirmative defenses against the Plaintiff’s Complaint

11. Please admit YOU have no documents to support your affirmative defenses against the Plaintiff’s Complaint


1. Who is the named plaintiff in the suit: Myself and my wife ( doe)

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) CACH, LLC

3. How much are you being sued for? $17762.12

4. Who is the original creditor? (if not the Plaintiff) Bank of America

5. How do you know you are being sued? (You were served, right?) I was served

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

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

Process Service Requirements by State - Summons Complaint

8. What was your correspondence (if any) with the people suing you before you think you were being sued? I denied all accusations, but only to CACH LLC

9. What state and county do you live in? Washington state

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) 5 years ago. SOT is 6 in WA

11. What is the SOL on the debt? To find out: 6

Statute of Limitations on Debts

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or B) looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Summons served to me and hearing date on 4/1/16

13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) As above I responded to summons to CACH LLC denying debt

14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. NO

15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? Hearing is on 4/1/16 and I have to file with the court by then.

Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits

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


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