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Interrogatories and Request for Production

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I am filling out request for Production, I know I want the Full Purchase Agreement from Cavalry.  This is for a debt collection lawsuit by a JDB.   They have given me the Bill of Sale twice now and added a couple more monthly statements.  

1.).  Should I request all the statements?  

2.).   What questions should I ask?

3.).   If I don’t ask one on this form can it be asked later at trial? 

They have filed a Motion for Summary Judgement and that is due tomorrow.  I just found out about this TF 255 form to request info and ask questions.   I called clerks office and asked if it was too late to do this.   That person was not sure but said to go ahead and fill it out, send it to Cavalry.   I am attaching it to my opposition to Motion for Summary Judgement so the Judge will know I’m not giving up. 

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Who is the OC?  What is the amount of the debt (ballpark number)?  It might be too late, as the case appears to have gone pretty far, but have you considered arbitration?  Is there an arb clause in the OC cardmember agreement?  If you want to pursue arb, you should not file discovery.

Alaska is a GREAT state for the arbitration strategy.  Under consumer rules, you are entitled to an in-person hearing, in your home town.  The JDB has to pay the arbitrator's fees and travel expenses.  Usually they will give up.

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