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Need Help with Answers to Plaintiff's Request for Admission, Interrogatories and Production

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Hello, I am new here and I am being sued by LVNV Funding. I am currently in the discovery phase as I didn't know that I should have initially filed a motion to dismiss because there was no contract attached to the complaint filed against me. I live in Mississippi and have been researching my court's rules but some of the questions I have been asked I am having hard time answering. Any help that can be provided would be GREATLY appreciated.


Here are the interrogatories I am having trouble answering.


1.Should you deny any of the requests for admissions above, please set forth in complete detail the extent of the effort made by you to ascertain the truth of the above request for admission and the factual details for all facts supporting any denial or qualified or qualified admission of the foregoing request including any and all witnesses (including their respective addresses and telephone numbers) you intend to rely upon at a trial of this matter in support of your denial.

2.  Identify each and every person consulted in connection with your preparation of answers to these Interrogatories. For each person consulted, please identify his or her relationship with you, the topic you discussed and the nature of the conversation.

3.Identify each and every document in Defendant’s or Defendant’s attorney’s or representative’s custody or control which relate in any way to any defense asserted by Defendant to the Complaint filed by the Plaintiff in this cause, or any other issue presented in this action, also providing the name, current address and telephone number of the custodian of such documents.

4. Has the Defendant commenced, or been a party to, any bankruptcy proceeding prior or subsequent to the filing of Defendant’s responses to these interrogatories? If so, state the style and cause number of such case, the court in which such bankruptcy action if or was pending, and the current status or final disposition of such actions.

5. If you deny that you are indebted to LVNV FUNDING LLC for the amount claimed in this suit, please describe in detail each and every basis for your denial of the indebtedness.


Here are the request for production that i am having a time trying to gather the right wording.


1.  Should you deny any of the requests for admissions above, please produce any and all documents or things supporting any denial or qualified denial or qualified admission of the foregoing request.

2. By the request for production of documents or things, please produce any and all documents identified in your responses to interrogatories propounded in this action.

3.   By way of request for production of documents of things, please produce any and all materials given to, or relied upon by, any expert witness retained by Defendant in formulating his or her opinion.

4.   By way of request for production of documents or things, please produce all documents and tangible items which support any defense, whether affirmative or otherwise, set forth in Answer to the complaint.

5.   By way of request for production of documents or things, please produce all statements or other documents identified in response to Interrogatory No.17 served simultaneously herewith. Interrogatory 17 is listed right below and my anwer.


Interrogatory 17

17.      Has Defendant had any conversations or written communications with Plaintiff, its agents or representatives, regarding all allegations alleged in the Complaint? If so, state:

1.      The parties to such conversation or communication;

2.      The date of such conversation or communication;

3.      The substance of such conversation or communication;

4.      The name and employment position of any employee of Plaintiff with which Defendant, or Defendant’s representatives, had such a conversation or communication;

5.      A description of any written documents or tangible items reflection the existence, or substance of, such conversations or communications.

 Answer: Defendant objects to Plaintiff’s interrogatory No. 17 as Plaintiff claims to be the assignee of alleged account therefore Plaintiff should have records of conversations and written communications. Also; interrogatory is compounded and contains sub parts.


6.    By way of request for production of documents or things, please produce all bank records and statements with respect to all bank accounts described in Interrogatory No. 10, above, for January 1, 2015, to the present. I've listed interrogatory 10 below and my answer.

Interrogatory 10.

10  List the name and address for all banks or financial institutions where you presently maintain a checking, savings or similar type of account, including the corresponding routing number and account number for each account.

  Answer: Defendant objects to Interrogatory No. 10 on the grounds it irrelevant and invasive of the Defendant’s privacy. Plaintiff has provided no evidence sufficient to overcome Defendant’s privacy interests. Also; interrogatory is compounded and contains sub parts





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