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Request for Admission of Fact from Calvalry SPV LLC


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I need some help ASAP! My daughter received this request for admission of facts from Calvalry SPV and we live in Louisiana. It states:

Plaintiff herein calls upon the defendant to answer the following requests for admissions of fact within the delays allowed for in accordance with the Code of Civil Procedure Article 1466:


It is a fact that Calvalry SPC I, LLC is the owner of all rights, title and interest in this receivable issued through GE Retail Bank


It is a fact that your outstanding balance on the account is $2937.74, together with additional interest of 4% interest from date of judgement.


It is a fact that you applied for and were issued a(an) Care Credit account bearing #***********47082102.


It is a fact that interest and attorney's fees are authorized either as a result of statute and notice or through your agreement with the creditor.

I know Louisiana has a statue of limitations of 3 years for credit card debt and her last payment on this was Nov. 2014. I also know that Calvalry is a debt collection company. 

Is there a sample letter of how to answer these questions because it has to be completed this week and I have no clue where to begin! She knows the debt is owed but she is still in the process of community property settling and the ex isn't making it go any faster. He keeps it tied up in court constantly so he doesn't have to pay anything right now. 

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#1 objection.  This request calls for legal speculation. 

#2 objection.  Ambiguous. "Account" has not been defined. 

#3 you may have to admit this if you know that account # is correct. If you don't remember the account #, defendant is without knowledge or information to form a belief as to the the truth of request #3 and therefore denies. 

#4 objection. Calls for legal speculation. 

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