Need Help With Special Interrogatories/Admissions Responses

[goatstache]

Hello all,

I'm hoping I can get some help finishing up responding to these Special Interrogatories.  These are due soon and any help would be greatly appreciated!  Here is some information about the case -  I was sued by Patenaude & Felix for a student loan that was transferred to National Collegiate Trust.  I responded with a general denial affirming that I had at one point had a loan with the Original Creditor but denied all other claims stating that I didn't have enough information to admit nor deny the allegations of the amount etc. and so I denied them.  Below are the interrogatories.  I need to type up the Admissions still.

_______________________________________

 

Special Interrogatory No. 1:

State the approximate date YOU (for the purposes of these interrogatories, the term “YOU” and “YOUR” refer to Defendant(s) ______, and his or her agents, including but not limited to his or her attorneys, direct or indirect employees of or connected with his or her attorneys, anyone acting on his or her behalf, or anyone subject to this or her control) opened loan number ______ as referenced in the Note Disclosure Statement attached as Exhibit “1” to this discovery request with Original Creditor ________.

Response No. 1:

 

Special Interrogatory No. 2:

State each and every fact, circumstance and/or evidence which in any way supports or substantiates YOUR contention that there is no amount due, owing or unpaid by YOU to Original Creditor ____. or Plaintiff National Collegiate Student Loan Trust 2.

Response No. 2:

Objection.  Premature as it requests information from the Defendant, prior to the completion of discovery, to state all the facts supporting its present contentions and to speculate as to its future contentions.

 

Special Interrogatory No. 3:

State in detail each and every fact, circumstance and/or evidence of any dispute(s) remaining unresolved between YOU and Original Creditor ______  or Plaintiff National Collegiate Student Loan Trust.

Response No. 3:

Objection.  Premature as it requests information from the Defendant, prior to the completion of discovery, to state all the facts, circumstances and/or evidence of any dispute(s) remaining unresolved.

 

Special Interrogatory No. 4:

State all facts upon which you base your denial of any of the paragraphs on the Complaint in this action.

Response No. 4:

 

Special Interrogatory No. 5:

State all facts upon which you base each affirmative defense to the Complaint in this action.

Response No. 5:

Defendant did have an agreement _________.

 

Special Interrogatory No. 6:

State the dates and amounts of any and all payments made by YOU to Original Creditor _______. or Plaintiff National Collegiate Student Loan Trust, or any other assignee, within the last four (4) years.

Response No. 6:

After a reasonable inquiry and diligent search, the Defendant does not have any of the requested information.  The Plaintiff should already be in possession of any such information if it exists.

 

Special Interrogatory No. 7: 

State each and every date within the past 4 years wherein YOU disputed the charges with Original Creditor ________ or Plaintiff National Collegiate Student Loan Trust, or any other assignee, which form the basis of Plaintiff’s Complaint.

Response No. 7:

Defendant does not recall whether or not there have been any disputed charges within the past 4 years.

 

Special Interrogatory No. 8:

State the name, address, and telephone number of YOUR employer.

Response No. 8:

Objection.  Not relevant to the subject matter of this action.

 

Special Interrogatory No. 9:

For each and every denial in Plaintiff’s Request for Admissions, state the reason for such denial.

Response No. 9:

[goatstache]

Bump

[Clydesmom]

On 9/23/2016 at 3:32 PM, goatstache said:

State the approximate date YOU (for the purposes of these interrogatories, the term “YOU” and “YOUR” refer to Defendant(s) ______,

Question:  did they omit the name of the OC or did you in retyping this?

[goatstache]

I omitted when retyping.  

[sadinca]

how long do you have to answer the request?

did you ever serve a Bill of Particulars?

 

 

[goatstache]

I haven't served for a bill of particulars yet.  We just had our first court appearance to schedule dates.  My answers are due at the end of this week.