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Sued by Discover Bank Oklahoma


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Please help me. I am trying to respond to Request for admissions, interrogatory, and production from Plaintiff.  How would you recommend I respond to these?

INTERROGATORY NUMBER 12: List the name of the institution, the account number and each and every owner for each and every bank demand deposit agreement you had with any banking institution from 05/19/2013 to 06/30/2016.

INTERROGATORY NUMBER 13: List each and every defense that you intend to assert in this matter and a brief summary of the facts that are within your knowledge which support the defense.

INTERROGATORY NUMBER 14: List each and every witness that you intend to call at the trial of this matter and give a brief summary of the anticipated testimony of the witness.

 

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1 hour ago, DarkOne said:

INTERROGATORY NUMBER 12: List the name of the institution, the account number and each and every owner for each and every bank demand deposit agreement you had with any banking institution from 05/19/2013 to 06/30/2016.

OBJECTION:  Overly broad and burdensome on the Defendant and the material requested is irrelevant to the claim(s) made by the Plaintiff in their filing.  The information requested is not destined to reveal information material to the case as filed.

1 hour ago, DarkOne said:

INTERROGATORY NUMBER 13: List each and every defense that you intend to assert in this matter and a brief summary of the facts that are within your knowledge which support the defense.

This is where you list your defense(s) to their suit.  For example if the statue of limitations had expires I would say:

Statute of Limitations.  Plaintiff states the last payment on the alleged account was [date] and the SOL in [state] is 3 years and the Plaintiff filed on [date] and therefore is barred by the SOL from pursuing the claim.

1 hour ago, DarkOne said:

INTERROGATORY NUMBER 14: List each and every witness that you intend to call at the trial of this matter and give a brief summary of the anticipated testimony of the witness.

This is where you list any witnesses if you have any.  If you don't:

Defense has not witnesses at this time however, discovery is ongoing and reserves the right to amend the witness list with appropriate notice to Plaintiff and representing counsel.

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