Interrogatory help
Date: Sun, 02/21/2010 - 09:38
Received interrogatory and production request with 49 interrogatories and 9 production questions which seemed overly burdensome if I read properly some quidelines in Pennsylvanis Rules of Procedures.I sent 19 interrogatories and 4 production. My primary line of defense so far has been failure on the part of the collection agency to validate properly. They sent a 2 page account summary in response to my validation and signed agreement demand after the dunning letter and then with the summons added a verification letter with no corporate seal, notary just a statement that the signer is an employee of the original creditor. My question is-- some of the questions ask for such things as when was last payment made, how much was paid,etc. I intend to answer that I can neither confirm nor deny because of failure to send a signed contract or respond by stating original creditor has the information and will be required to present same during discovery. Any other ideas please?
I'm giving this a little bump in the hopes someone will see it a
I'm giving this a little bump in the hopes someone will see it and respond!
Object to the "signer" of the employee letter as hearsay. Deman
Object to the "signer" of the employee letter as hearsay. Demand to see this signer in court and prove they have direct knowledge of your account. The account summary is partial validation if the amount on the summary matched the amount being sued for. Plus, if the agreement is signed by you, that would constitute proper validation as well. Your idea for the answers is good, it is not up to you to produce the evidence for them. You can't provide last payment information and such on accounts that are in question of existing. :)
