Urgent help responding to Request For admissions, Documents and Interrogations

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I was sent a Request For admissions, request for Documents and Special Interrogations and need help answering them. I have seen a general response to admissions in this forum and may use similar,  but regarding the documents, I don't have anything? The original contract was online and I printed, signed and sent back via fax. I have no record of anything else. Then, regarding the Special Interrogations, I have no idea how to answer. I would like to just settle with them but without sending this in I am going to be in trouble. My wife was battling breast cancer in 2019 and 2020 and I became her and our 3 children's primary caretaker. This is why we fell behind. They don't care at all as I tried to explain. Any help answering these would be greatly appreciated as I must get it out in the mail this week to meet the deadline. I also need help in sending them discovery. I am willing to pay someone what I can afford to help me. $100 or so? TIA to anyone who can help. I have attached the documents they sent that I must respond to but I omitted my personal information and case numbers, etc. 


Document_2021-04-24_145859take2.pdf Document_2021-04-24_145859take2.docx

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You don't have to admit anything on their Request for Admissions.  If you've had an account with Citibank, and used it, and received monthly, you can choose to admit those facts.  I did on mine.  However I've denied pretty much the rest, like having an unpaid balance due, or that I owed them, etc.  You can also say something like "I can neither admit or deny this request as I have no memory concerning it and no records of it and the information known to me or readily obtainable by me is insufficient to enable me to admit or deny." if you're not sure.  You must also deny that you don't have affirmative defenses.  You do, because "lack of standing" is one of them.  You don't know that Citibank has sold your account to LVNV Funding.  You can claim other affirmative defenses even if they may be applicable.

On the Request to Produce Documents, you can send them whatever you have, but if you don't have anything else, you don't need to.  They are the ones who will have to prove that you've used the credit cards, and more importantly, that LVNV Funding really owns your debt now.  These junk debt buyers usually don't have enough evidence to prove this.

On the Interrogatories, you can state what you're comfortable stating, but you can also say something like "Discovery is still ongoing, and Defendant reserves the right to amend, supplement or change its objections and responses if and when additional information becomes available." if you don't want to say that you don't have anything currently.

After you respond to their discovery requests, you can send them the DEMAND FOR BILL OF PARTICULARS (BOP) or request a set of discovery requests of your own.  You've mentioned that you're looking to settle, but you can choose to fight the lawsuit until the end and win it.  However you will have to put in a lot of time into it.  I know you probably don't have the time because you're taking care your wife and the kids... so whatever you decide to do....I wish you the best of luck!

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4 hours ago, ticklemore said:

You don't have to admit anything on their Request for Admissions.  If you've had an account with Citibank, and used it, and received monthly, you can choose to admit those facts. 

One can also check their rules of civil procedure on  discovery.  Many allow a defendant (or plaintiff) to state “Defendant has insufficient information to admit or deny and, therefore, denies”.  That’s especially useful if the other party send little or no supporting documentation such as a credit card statement, etc.   

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Thank you both so much! Regarding the answers to special interrogatories, if I don't recall or have anything, what would I say? Like the 1st question they ask is to "state all facts which base that I owe nothing on the account".  Can I just use the same blanket answer I did with admissions or go with the suggestion you had under special int. that state discovery is still ongoing? 

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"Admit nothing, deny everything" is my motto. I admitted to my name when I responded to mine, denied everything else and objected to any interogs & documents requests that were worded in a 'tricky' fashion.

Might be able to find a sample set of answers in a previous Citi/Mandarich thread - JDBs use the exact same questions just about every time so they usually aren't hard to respond to.

When are your answers due, @NeedsHelpPlease ?

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