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To keep it a little anonymous I'm leaving out the creditor names... Thank you for all your help. It's very much appreciated right now.
Admissions
1. You applied for credit privileges, or took money advances under a credit card or line of credit or promissory note loan with xxxx
2. You were extended monies under xxxx formerly xxxx under account number xxxx.
3. You or persons authorized by you, made purchases/or received cash advances, or took money advances under a credit card or line of credit or promissory note/loan under xxxx formerly xxx under account number xxxx.
4. You received monthly statements concerning "account number" specifying previous balance, new purchases; payments; finance charges, minimum payments, new balance or line of credit or promissory note/loan.
5. You promised to re-pay for the monies extended by xxxx formerly xxxx under acct number xxxx.
6. You did contest the amounts reflected on the monthly statements within 60 days as provided by law.
7. XXXX, formerly XXXX under acct number xxxx which is the subject matter of this suit went into default for non-payment?
8. The sum alleged to be due and owing on xxxx formerly xxxx under acct number xxxx in this complaint is accurate?
9. You agreed to pay contractual attorney's fees in the event the account, which is the subject matter of this suit was referred to an attorney for collection?
10. The balance due as set forth in the last monthly statement sent by xxxx under accout number xxxx before referral to collection in the amount of suit amount is in fact due and owing?
11. Do you admit that (ME) is the owner of XXXX formerly xxx under acct number xxxx.
Interrogatories
1. Identify the name of the individual responding to these and relationship
2. State Defendant's full name and current home address
3. State addresses defendant has resided for last 10 years
4. State defendant's occupation and how long defendant has been employed as such.
5. State the addresses the defendant has worked over the past 7 years.
6. Does defendant acknowledge that defendant entered into an agreement with plaintiff or predecessor in interest?
7. Did the defendant ever authorize anyone to open and maintain any account with the plaintiff or predecessor in interest on your behalf.
8. If the answer to #7 is yes, identify the person given authorization. Was it verbal or oral?
9. If written, set forth a copy of said authorization. If oral, set forth the suman and substance of the oral authorization, when it was entered into, where, and who acted on each parties behalf.
10. Did Defendant at any time receive any written communications from Plaintiff?
11. If the response to #10 is yes, identify written communications and produce true copies.
12. Did defendant ever receive monthly statements from Plaintiff?
13. If #12 is yes, identify dates the statements were received.
14. If the answer is yes, did defendant ever dispute the amount either in writing or orally? If yes, did defendant at any time dispute the account in writing or orally?
15. If written, please attach copies of all communications.... If oral, please state to whom you spoke, approx. date and times and substance of the conversation.
16. Did the defendant ever make any payments to Plaintiff?
17. If yes, please attach any checks, money orders or any other means by which payments were made to Plaintiff. Identify the date that each payment was made and the amount of each payment tendered.
18. Does defendant claim that defendant is not the correct party to this action?
19. If yes, identify the party the defendant believes should be responsible for the debt.
20. If the answer to #18 is yes, specify how defendant received notice of this lawsuit.
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