Affidavit of Debt - can I ask about this?

[scottchopchop 0]

In my REQUESTS FOR ADMISSIONS, INTERROGATORIES, AND REQUEST FOR PRODUCTION OF DOCUMENTS, can I ask questions about the Affidavit of Debt which the Plaintiff attached to their Petition?

[BV80 2,797]

20 minutes ago, scottchopchop said:

In my REQUESTS FOR ADMISSIONS, INTERROGATORIES, AND REQUEST FOR PRODUCTION OF DOCUMENTS, can I ask questions about the Affidavit of Debt which the Plaintiff attached to their Petition?

What are the questions?

[scottchopchop 0]

Specifically I was wondering about asking questions about the Affiant, asking for documents related to the Affiant.   

[BV80 2,797]

10 minutes ago, scottchopchop said:

Specifically I was wondering about asking questions about the Affiant, asking for documents related to the Affiant.   

You can ask questions in the interrogatories, but you need to ask in a way that requires more than a “yes” or “no”. 

If you want specific documents, those are demands made in the request for production of documents.

What documents relating to the affiant?

[scottchopchop 0]

In the ADMISSIONS section I considered asking them to admit some things related to the that affiant's lack of personal knowledge about the account during a certain period.

I considered asking for Documents related to the Affiant's training and employment history.  I would also like to know how many of these sorts of Affidavits the Affiant has signed in the past few years and I'd like ot see some related documentation.

Would I be barred for any reason to ask for those sorts of Admissions and Documents?

Are there any questions about Affiant that I am barred from asking?  

[BV80 2,797]

30 minutes ago, scottchopchop said:

In the ADMISSIONS section I considered asking them to admit some things related to the that affiant's lack of personal knowledge about the account during a certain period.

You can try, but they won’t admit anything negative.

30 minutes ago, scottchopchop said:

I considered asking for Documents related to the Affiant's training and employment history.  I would also like to know how many of these sorts of Affidavits the Affiant has signed in the past few years and I'd like ot see some related documentation.

Again, you can try, but I doubt they’ll provide such documentation.   The employment history and number of affidavits signed would probably be considered irrelevant.  It would be up to you to show why (via evidence and case law) documentation on the training and employment history is necessary for plaintiff to prove its claims and for the admissibility of the affidavit. 

In the interrogatories, you could request they describe in detail the training the affiant received to prepare her for her current position as ______________ (whatever position she claims she holds in the affidavit).