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Bill of Particulars under Money Lent NOT PROVIDED. What should I do next?

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Hi, while I am still in the discovery process (Card debt from a Debt Junk Collector) I requested the Bill of Particulars to the Plaintiff.

Because I was sued for (1) Account Stated, (2) Money lent. ($8,000 card debt)>The Plaintiff objected to provide the Bill of Particulars based on Account Stated, however, they  "provided something (not really)"  under the Money Lent cause. (same copies of card statements)

The problem is that they objected to provide anything on the grounds of confidential communication crap between Plaintiff and their attorney. They also claim that because discovery is still open they are still working on investigating the case and they need time to prepare the case.  Last sentence reads...."Plaintiff reserve the right to amend or supplement their responses bla bla bla".

Plaintiff wrote the following under the Money Lent cause: Plaintiff is only required to produce an itemization of the account alleged within the pleadings indicating what accounts are subject of the lawsuit. Plaintiff has has bee contacted by its attorneys of records Law offices of Junk Suckers, APC and hereby complies with this Bill Of Particulars: A diligent search and reasonable inquiry has been made in an attempt to locate the requested documents. Plaintiff is continuing to search for its records for documents that are responsive to demand. bla bla bla, they only sent a copy of previously sent card statements, nothing else, nothing new.

 

I read here in this forum that I should send a Meet and Confer letter requesting the missing documents for the BOL before I file a Motion to Compel the BOP.

Do I need to give them more time to produce the itemization accounting for the debt? Will the OC create such document?

When does discovery ends?

I answered their RFE  (1) and I sent my own set (1) RFE too. (Interrogatories, Request for admissions and Production of documents.

Than you,

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