Got it. My notes to each question are below:
No. 1: State the name, address and position or title of each and every person who has answered, provided any information, has been consulted, or has participated in the preparation of the Answers to these Interrogatories. For each such person identified, state which Interrogatories each answered or provided information used in answering.
Notes - This is a standard question. Just list your name unless you have an attorney or accountant or some third party which is helping you.
No. 2: If You assert that the claim herein sued upon is the obligation of anyone other than Yourself, then state: (a) The name and present address of each such other person; (b) All of the facts upon which You rely in support of such position; (c) Your relationship to such other person or persons.
Notes - this is a legitimate question. Does the debt over which they are suing belong to someone other than you? If so who?
No. 3: If you feel there is any reason whatever why You do not owe the claim or debt sued upon, and if You have not fully stated such in response to the preceding Interrogatory, then state such reason or reasons here, and all facts relating thereto, without regard to any legal opinion as to the validity of same.
Notes- This is a legitimate question. Is there any reason you feel that you do not owe the debt? However, I would object as follows: "Objection, this interrogatory is overly broad in that it seeks to force Defendant to marshal all its evidence and improperly attempts to place the burden of proof
on Defendant in this case. Subject to the foregoing objections and without waiving the same, Defendant believes_____________(state why you dont' think you owe it, if you have a good reason...if you don't then just leave the objection as it is without this last sentence).
No. 4: Identify each person You are aware of who has knowledge concerning the facts and circumstances surrounding the matters which are the subject to the claims made against You in this lawsuit. For each such person, please state: (a) Name; (b) Occupation; (c) Business and residence address and telephone number; (d) A detailed summary of the matters within the knowledge of each person.
Notes - this is a legitimate question and you should answer to the best of your ability.
No. 5: Identify each and every document in your control or possession, or within Your knowledge, that in any way refers or relates to any defenses which You assert in this matter. With respect to each Document, please state: (a) The date of said Document; (b) The substance of the information set forth in said Document; (c) the present location of the original or, if there is no original, photocopies of said Document. In the alternative, you may attach copies of said Documents to Your Answers.
Notes - This is a bogus request. Reply with this objection only: "Defendant objects to this interrogatory on the grounds that it is overly broad, vague and ambiguous, failing in its entirety to identify with specificity the exact type of information requested and further attempts to force Defendant to marshal its evidence."
No. 6: State specifically and completely the factual basis of each and every defense, whether set forth in Your Answer, or otherwise, which You assert in this action. For each such defense, please provide the following: (a) State each and every fact upon which You base said contention; (b) State the name, address, and last known employer of each and every individual whom You believe has knowledge of the facts and circumstances upon which You base said contention; (c) If any such fact is referred to or embodied in any Documents, describe each Document with sufficient particularity to serve as a basis for a separate request for production of Documents. In the alternatives, You may attach copies of said Documents to Your Answers.
Notes - this is a fair question. What are the facts which back up your defenses. However, I would begin with an objection: "Objection, this interrogatory is overly broad and attempts to improperly exclude evidence which is not included in the response to the same, and in other words, attempts to force Defendant to marshal its evidence. Subject to the foregoing objections and without waiving the same, Defendant response as follows...."
No. 7: State specifically and completely each and every act which You allege Plaintiff failed to perform in accordance with any agreement between the parties, which act(s) were precedent to any obligation by You to pay Plaintiff.
Notes - If you have alleged this, then you need to explain what the Plaintiff did that shows that they should not be paid.
No. 8: List the addresses of every place where you have resided for the last ten years, and if you had your mail sent to another address, please list those addresses as well. Please identify whether the address was used as a residence, for mailing purposes, or both.
OBJECTION will be made at the time of trial to any attempt to introduce evidence which is sought by this discovery and to which no timely disclosure has been made.
Notes - This is a fair question and needs to be answered.
REQUEST FOR PRODUCTION OF DOCUMENTS
Notes - You need to gather all the documents you have regarding the debt, copy them and produce them as an attachment to your responses.
No. 1: All documents relating to the alleged debt of Defendant.
Notes - Objection, this request is overly broad, vague and ambiguous. Defendant is not in possession of all responsive documents. Further, this request attempts to force Defendant to marshal its evidence improperly. Subject to the foregoing objections, please see the attached responsive material.
No. 2: Every billing statement you have in your possession for the alleged account.
Notes - fair and needs to be produced
No. 3: All exhibits which Defendant proposes to introduce at trial.
Notes - Objection, Defendant is not required to produce its trial exhibits until ordered to do so by the court in its pre-trial order. Further, this request is overly broad, vague and ambiguous, improperly attempting to force Defendant to marshal its evidence.
No. 4: All sides of all checks that you contend constitute payment of any part of Plaintiff's claim and for which no credit has been given.
Notes - this one is fair...you need to try to retrieve these from you bank as well.
No. 5: Any letter or communication sent to the creditor disputing the alleged account.
Notes - this is fair.
No. 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 the subject of this litigation.
Notes -Objection, this request is overly broad, vague and ambiguous. Defendant is not in possession of all responsive documents. Further, this request attempts to force Defendant to marshal its evidence improperly. Subject to the foregoing objections, please see the attached responsive material.
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