I am representing a client in a credit card dispute with ...

Reply to Law Girl's Post: As I said earlier, I've a client in a dispute with credit card giant Chase Bank USA, N.A. This person was solicited by the credit card company. He at first demurred because he was a resident alien awaiting permanent residency and a Social Security number. Chase pressed the offer anyway, saying he could transmit the Social Security number to them when it was issued. He got a MasterCard and then a Visa, both with healthy credit limits, which he used in the service of his business. He received his Social Security number and provided it to Chase, also requesting an increase of the MasterCard's credit limit, which was approved. He used both credit cards freely, making all payments on a timely basis and above the minimum required amount. Shortly thereafter, he was contacted by Chase, which accused him of fraud. They sent him two (2) promissory notes for the outstanding balances on both cards. Because the terms were very onerous and there was language which would have required him to admit to the perpetration of fraud, however, he refused. Chase proceeded to contact his creditors, telling them my client had fraudently purchased their goods and demanded repayment. The creditors complied and then demanded reimbursement from my client. He complied but was then left without credit and a liquidity crisis. Chase then contacted my client's bank, repeated the allegations of fraud and demanded repayment for the outstanding balances from his bank accounts. The bank refused but then froze the accounts and eventually closed them. At some point, Chase must have realized an error had been made because they, without informing my client, issued two (2) new credit accounts, into which they transferred the balances from the old closed accounts. My client discovered this development only when, in the midst of an attempt to refinance his home, a credit report was issued which displayed the two new credit card accounts. Chase then proceeded to demand payment for the new accounts and now regards XXXXX XXXXX past due.

In any case, Chase sued, we have filed a counterclaim alleging defamation and violations of Florida's Consumer Collections Act as well as the Deceptive and Unfair Trade Practices Act. We are considering filing an amended complaint alleging violations of the federal Truth In Lending Act. At present, though, we have entered discovery and so I would appreciate any guidance on how to craft crackerjack Interrogatories and Request for Production of Documents. Any examples of past work on your part would be very welcome. Thank you

Dear Moderator:

I have received a reply to my request for information but the sender needs access to my e-mail address in order to send attachments. Any help you could provide in this regard woud be greatly appreciated.

Thank you.

Cordially yours,
Joseph TomeReply to Law Girl's Post: Dear Kat,

I believe I have sent a message to the moderator asking him/her to provide you the access needed. I hope to hear from you soon.

Cordially yours,
Joseph Tome