Consumer Protection Law
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I redid #3 #4 and #6 as you suggested, I also have a request for production so I didnt redo #5 and I plan to send it certified mail and file it with the court the only documents I have are a letter I recieved 2 years ago from another attorney saying I owed this so I replied with a letter asking for the items in #3 and never heard anything until just recently a summons so I dont have any documentation really
Will you look over my request for admissions and request for documents too
RE: Request for production of documents
1: All documents relating to the alleged debt of defendant
Response to request 1: I will send anything related to this matter that I have in my possession
2: Every billing statement you have in your possession for the alleged account
Response to request 2: I do not possess any for alleged account
3:All exhibits which defendant proposes to introduce at trial
Response to request 3: I will send anything related to this matter that I have in my possession
4: all sides of all checks that you contend constitute payment of any part of plaintiffs claim and for which no credit has been given
Response to request 4: No such checks are in my possession
5: any letter or communication sent to the creditor disputing the alleged account
Response to request 5: I will send anything related to this matter that I have in my possession
6: all documents claimed to support any defense, affirmative defense, or counterclaim, including but not limited to, bank statements, account statements, and written correspondence exchanged between plaintiff and defendant concerning the credit card account which is subject of this litigation
Response to request 6: I will send anything related to this matter that I have in my possession
RE: Request for Admissions
1: You applied for credit account with HSBC Consumer Lending (usa) Inc.
1: Deny - I had an account with HSBC. I have been presented no evidence that the account I had with HSBC is the same account as the debt alleges in this complaint
2: HSBC consumer Lending (USA) INC., granted you credit under the account number ending in ****4166
2: Deny – I have no record of an account ending in **** 4166
3: You received a copy of the credit agreement when you applied for credit with HSBC
3: I can neither admit nor deny this request because I don’t know
4: Plaintiff Atlantic Credit is now the owner of the account originated with HSBC
4: I can neither admit nor deny this request because I don’t know
5: Attached hereto as Exhibit “a” and incorporated herein by reference is a true copy of the assignment and bill of sale between HSBC to plaintiff
5: Object exhibit A lists nothing with my name on it however, subject to and without waiving the foregoing objection I would answer: Yes there is an a document attached with the designation EXIBIT A
6: You received a copy of the credit agreement and any amendments that governed that account
6: Deny - I received nothing about “the account”
7: You used or authorized the use of the credit granted to you under the account number ending in ****4166
7: Deny – I have no records or have not been shown any records of this being true
8: You received statements from HSBC, reflecting how much you owed on the account
8: Deny – I have not been shown anything
9: You did not dispute any of the charges with HSBC in writing
9: I can neither admit nor deny this request because I never received anything from HSBC to dispute in writing
10: Payment was demanded of you and you have refused to pay
10: Object, this request for admission is vague and burdensome and is confusing in its intent. However, subject to and without waiving the foregoing objection I would answer: I admit I have not paid because I do not believe the account is mine
11: The current amount owing on the account is $xxxx.xx
11: I can neither admit nor deny this request because I don’t know
what is bates stamp?
all I have is some letters one from an attorney 2 years ago saying I owed and asking for payment my response letter that basically asked for all the details of the debt and if they werent provided to me within 30 days he needed to delete and remove anything from my credit file and that was in April of 2011 then March 19th of this year I got a summons saying I was being sued I answered it on april 18th then this discovery on July 8th I dont know if those count as documents and if so I have no problem sending copies to them
do I need to send requests for documents and admissions or interrogatories?
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