What does this mean? I am so sick of this!

Hi Mary--

They are claiming that they already provided discovery to you, in other words. To propound means to put forth, to offer. They are saying that they sent forth discovery to you. My first question now is, what exactly did you ask for in discovery?

My second thought is this--they are claiming that they provided discovery already, and yet they are still trying for continuances. This is only an observation, but this is actually not that uncommon in cases like this. JDB's like CACH are great at filing lawsuits--but they typically have nothing to prove their case, so they file the lawsuit in the hopes that the defendant will either not answer, in which case they get a default judgment, or the defendant will show up and believe that the garbage CACH provided as "proof" is good enough. You showed up and then you questioned what they brought forth as "evidence". So their hopes are shot on both counts. It is once again only an observation, but my guess right now is that they know you know the laws as evidenced by your motion to strike, your knowledge of the hearsay laws, etc etc, and so they know they cannot wage this war with you. Before, I have seen cases go like this and after a couple of continuances, the plaintiff still has nothing new to provide, so the case often gets dismissed. BUT--this is very important--do NOT let your guard down with these crooks. Keep up on every detail, everything they send, every statement they make. STick to your guns. If you happen to have the chance to be in front of a judge, at a court date, it may not be a bad idea at this stage to request dismissal with prejudice, stating that the plaintiff has not at all met the required burden of proof that the law requires, and continuing this case further only delays that conclusion. At this point, if it were me, I would state that the plaintiff has the responsibility of being prepared before they file such a lawsuit, and that you should not be unjustly burdened by a continuing case in which the plaintiff clearly did not take the necessary time or effort to be prepared for their own lawsuit. then again, I do tend to be a bit, perhaps, cocky in this kind of situation. It is possible that if you put that pressure on the plaintiff, they will simply dismiss the case. It has certainly happened before.

Dont panic over this--stick to your guns. Dont let them get away with anything that the law doesnt allow them to do.

[QUOTE=skydivr7673;490136]Hi Mary--

They are claiming that they already provided discovery to you, in other words. To propound means to put forth, to offer. They are saying that they sent forth discovery to you. My first question now is, what exactly did you ask for in discovery?

This is what I sent to them for my Request for admissions and production of Documents.
In the next post I will post what they answered with and what they attached.
INTERROGATORIES

Interrogatory No. 1
Is CACH LLC the direct assignee of Wamu/Providian Bank? Or, is CACH LLC an assignee of an assignee? If there are additional assignees, identify each assignee, their business address, and telephone number.

Interrogatory No. 2
Identify when the alleged account was originally opened by the defendant and was subsequently charged off by Wamu/Providian Bank .

Interrogatory No. 3
Identify the person or persons answering these interrogatories. Include their business address, business phone number, and title within the Plaintiff???s Organization.

Interrogatory No. 4
Please provide the following information for each person known to the Plaintiff who has knowledge of facts relevant to this case, including but not limited to all persons interviewed by you, by your counsel, or by any person cooperating with you in the this action, giving a brief description thereof, for each person you may call as a witness in this case.
1. Name, address, and telephone number.
2. Place of Employment
3. Relation to the Plaintiff
4. The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Interrogatory No. 5
Please provide the following information.
1. Your Full Name
2. Your Full Business Name
3. Your Business Purpose (e.g. Creditor, Lender, Collection Agency, etc.)
4. Form of Business Organization (e.g. corporation, partnership, LLC, sole proprietorship, etc.)
Interrogatory No. 6
In regards to the contract or agreement alleged in this action, please state the following:
1. Terms of the Contract or Agreement:
2. Credit Limit Amount Financed in the Alleged Contract or Agreement:
3. Date and Monetary value of any valuable consideration received on the contract or agreement:
4. Date and Monetary value of any payments or credits alleged to be executed on the contract or agreement:

Interrogatory No. 7
Please provide the following information for each person who has had any involvement in any manner in any efforts on your behalf to collect or attempt to collect any debt (s) purportedly owing by Defendant.
1. His/Her Position
2. His/Her work address, telephone numbers
3. Nature and purpose of his/her involvement.

Interrogatory No. 8
Identify the persons or entities, regarding any debt(s), which you have attempted to collect from Defendant, identify all documents related or relevant to your contractual agreement(s) (Servicing, Assignment(s), etc.), or other business relationships with said persons or entities.

Interrogatory No. 9
Plaintiff or Attorney. Please Identify each person who has had any contact or communication on your behalf regarding Defendant???s purported debt(s), state when, how, where, and with whom said contact or communication occurred and in detail and with particularity the substance thereof.

Interrogatory No. 10
Attorney. Describe all collection activities, which you were authorized to perform for CACH LLC , and identify the terms of the agreement between CACH LLC and you pursuant to which you sought to collect this account.

Interrogatory No. 11
Describe procedure and policy with respect to the Maintenance, preservation, and destruction of documents, stating in your Answer whether any documents or things relating to any information Requested in these interrogatories, or related in any way to this lawsuit, have ever been destroyed or are no longer in your custody. For each such document, please identify the document, how, when and why each document was destroyed or otherwise left your control, the identity of any person who participated in any way in the destruction and/or action for destroying the document or to transfer it out of your control or custody; and if the document still exists, identify the person now having control or custody of the document.

Interrogatory No. 12
What document states in writing in support of your Complaint that the Defendant is indebted to pay the Plaintiff and when was this agreed statement in writing entered into?

Interrogatory No. 13
On what date did the defendant become indebted to the plaintiff for $2,040.95 plus any accrued interest?

Interrogatory No. 14
Identify all witnesses with evidence in support of your Complaint that the Defendant, entered into a contract and is indebted to the Plaintiff.

Interrogatory No. 15
State all actions taken to verify the accuracy and completeness of the accounts reported and state your procedures designed to assure the maximum possible accuracy of the information reported by you.

Interrogatory No. 16
What is the date that the defendant allegedly defaulted on the original account?

Interrogatory No. 17
What was the status of the alleged contract/account when acquired.

Interrogatory No. 18
What credit card purchases and/or cash advances were made on this account? When where they made?

Interrogatory No. 19
Please identify and describe each exhibit you will use in the trial of Cause No. CV-09-89.

Interrogatory No. 20
State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action.

Interrogatory No. 21
As to each defense set out in response to Interrogatory Twenty (20), above, state the following as to notification to Defendant of such defenses; (a) the date or dates when notification was given; ( the manner in which notification was given; and ?? the specific party or parties to whom notification was given.

Interrogatory No. 22
How much was this account purchased for from Wamu/Providian Bank?

Interrogatory No. 23
Do you have the Actual Contract between the Defendant and Wamu/Providian Bank? And do you have the Assignment Agreement between Wamu/Providian Bank and CACH, LLC?

REQUESTS TO ADMIT FACTS
The Defendant requests that the Plaintiff answer the following requests to admit facts pursuant to, and in accordance with, Arkansas Rules of Civil Procedure 36. If the Plaintiff objects to any requested admission, the reason therefore shall be stated. The Plaintiff's answer shall specifically admit or deny the requested admission, or set forth in detail the reasons why the Plaintiff cannot truthfully admit or deny the requested admission. A denial shall fairly meet the substance of the requested admission, and when good faith requires that the Plaintiff qualify an answer or deny only in part of the matter of which an admission is requested, the Plaintiff shall specify so much of it as is true and qualify or deny the remainder, again detailing the specificity of the denial of the part thereof.
Fact No. 1
Please admit that you were not assigned Wamu/Providian Bank obligations under the purchase agreement.

Fact No. 2
Please admit that you do not have the original or a copy of an assignment between you and Wamu/Providian Bank .


Fact No. 3
Please admit that there was no written agreement, signed by Defendant, between Defendant and Wamu/Providian Bank.

Fact No. 4
Please Admit that there is no written agreement between CACH, LLC and the Defendant.

Fact No. 5
Please admit that the defendant is authorized to pay the Original Creditor/Lender until he receives notification of assignment of rights to payment, and that payment is to be made to the assignee.

Fact No. 6
Please admit that you did not send the defendant any notification of assignment of the account or assignment of rights.

Fact No. 7
Please admit that as of the date you drafted your Complaint, you had no evidence admissible at trial that proves Defendant owes the debt.

Fact No. 8
Please admit that CACH, LLC are considered Debt collectors under the Fair Debt Collection Practices Act.

Fact No. 9
Please admit that you are barred under the Fair Debt Collection Practices Act ?? 1692 f(1) from collecting interest on any amount not authorized by the agreement creating the debt or permitted by law.

Fact No. 10
Please admit that you do not have the agreement to claim the amount(s) submitted in the complaint.

Fact No 11
Please admit that you do not have a copy of or the original Cardholder Agreement.

Fact No 12
Please admit that you did not transfer your alleged assignment rights over to The McHughes Law Firm, LLC in order for them to collect your alleged debt.

Fact No. 13
Please admit that The McHughes Law Firm, LLC is the real party in interest.

Fact No. 14
Please admit that if you did purchase the alleged account it was in default.

Fact No. 15
Please Admit that if this assignment is proven by you it was purchased for less than the amount submitted in your complaint.


Fact No. 16
Admit that no notification of attempt to collect on this debt was sent to the following address by CACH, LLC: 166 Ginger Road, Scotland, AR 72141

Fact No. 17
Please admit that you cannot provide documents proving CACH, LLC owns this debt.

DOCUMENTS TO BE PRODUCED
1. Please provide the actual credit card contract upon which your Complaint is based on.
2. Please provide a contract, agreement, assignment, or other means of demonstrating that the Plaintiff has the authority and was legally entitled to collect on the alleged debt.
3. Please furnish reasonable proof, such as an original, or copies of the assignment agreement or assignment agreements, transferring the alleged contract and/or account in question from Wamu/Providian Bank over to CACH, LLC to show an Assignment has been made and that CACH, LLC are the real party in interest.
4. Please provide a copy of the Assignment between CACH, LLC and Wamu/Providian Bank.
5. Please evidence proof of the Defendant???s alleged debt to Plaintiff, including specifically the alleged contract, between the plaintiff and defendant or any other instrument constructed solely for the purpose of creating a loan agreement between the Plaintiff and Defendant bearing Defendants signature and/or Please Produce the contract that legally requires the Defendant to pay the amount entered into complaint.
6. Please provide the original or copy of the account agreement that states interest rate, grace period, finance charge, assignment, and specifically the State Laws that the agreement and account are governed plus other important facts.
7. Please provide copies of the amount paid and/or the consideration due for the alleged contract/ account.
8. Please Provide an Itemized account of all transactions mentioned in Interrogatory Number Eighteen (18).
9. Provide the Record of Assignment that displays the information in Interrogatory No. 22.
10. Please provide all copies of manuals, procedures, and protocols used by Plaintiff regarding communication and regarding purchased debt.
11. Please evidence authorization of Plaintiff to do business, create loans, issue or extend credit, collect debts and/or operate in the State where the Plaintiff conducts their business.
12. Please evidence authorization of Plaintiff & Attorney to do business, create loans, issue or extend credit, collect debts and/or operate as a financial business in the State of Arkansas.
13. Please provide a document or documents(s) that proves you did send the defendant a notification of assignment of the account or assignment of rights.
14. Please attach any and all notices sent to Defendant by Plaintiff in regards to this account demanding payment.
15. Please attach copies of all statements generated while this alleged account was open with Plaintiff.
16. Please attach a complete and accurate history of the interest charged on this alleged account with Plaintiff. Show the exact dates those interest rates changed and list the various rates that were charged during the this debt and the exact method of amortization.
17. Please attach any and all notices sent to Defendant by Plaintiff announcing changes in interest, fees or penalties and/or the terms of this alleged debt.
18. Identify each Credit Reporting Agency (credit bureau) to which the Plaintiff reported defendant???s debt and the dates of each such report.
19. Please provide the original dunning letter that was sent to Defendant.
20. Please attach any and all notices sent to Defendant by Plaintiff in regards to account announcing transfer and/or assignment of credit card account from plaintiff to any collection agency or collection attorney.
21. Please attach a copy of the agreement with Plaintiff that grants The McHughes Law Firm,LLC Attorney(s) the authority to collect this alleged debt.

This is how they responded,

Facts 1,2,3,4,5,6,7 DENIED
Fact 8,9 Admit
Fact 10,11 Denied
Fact 12 Admit
Fact 13 Denied
Fact 14 Admit
Fact 15 Plaintiff objects on the grounds that the request is irrelevant to this breach of contract action.
Fact 16,17 Denied

GENERAL OBJECTIONS

1. Plaintiff specifically reserves the following: (1) the right to object to the use of these responses or information disclosed herein in any hearing in this proceeding or in any subsequent suit or proceeding: (2) the right to object to other discovery procedures involving or relating to these responses or information disclosed herein; and (3) the right , at any time, upon proper showing, correct or clarify any of the responses set forth herein.

2. Plaintiff objects to any and all discovery requests that purport to require Plaintiff to supply information and/or documents that are not limited in time. Requiring Plaintiff to respond in the manner requested would impose a significant and undue burden and expense.

3. Plaintiff objects to any and all discovery requests that are overly broad, unduly burdensome, or seeks information which is confidential, irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, or is beyond the scope of discovery as defined by Rule 26 of the Arkansas Rules of Civil procedure.

4. Plaintiff objects to any and all discovery requests that seeks to discover information protected by the attorney/client privilege or the attorney work product privilege.

5. These General Objections are incorporated into each of Plaintiff's responses as if specifically set forth therein. Stating specific objections to a particular discovery request does not in any way waive the General Objection.

RESPONSES
Interrogatory 1. See general objections.
''2. See attached
"3. Clayton J Smith, Associate Attorney, The McHughes Law Firm, LLC Little Rock, AR
"4. Plaintiff has not identified each person who may have knowledge of facts relevant to this case or
each person it may call as a witness in this case; however Plaintiff intends on calling various as yet unidentified employee of CACH, LLC. These responses will be supplemented as additional information becomes available.
"5. See response No. 3
"6. See general objections; however, see attached. These responses will be supplemented as additional information becomes available.
"7. See general objections. Without waiving said objection, see response No. 3.
"8,9,10,11 See general objections.
"12. Please see attached. These responses will be supplemented as additional information becomes available.
"13. Please see attached
"14. See response No.4
"15,16,17 See general objections.
"18. Plaintiff has requested billing statements and will provide upon receipt.
"19. Plaintiff has not identified each it may use in the trial Cause No. CV-09-89; however, please see attached. These responses will be supplemented as additional information becomes available.
"20,21 N/A
"22. See General objections.
"24. Plaintiff has ordered requested documents and will provide upon receipt.
Plaintiff will comply with the dictates of the applicable rules of Arkansas Rules of Civil Procedure.

Documents to be produced
Response:
1,2,3,4,5,6,7, Plaintiff has ordered requested documents and will provide upon receipt.
8,9,10,11,12, See General objections.
13, Plaintiff has ordered requested documents and will provide upon receipt.
14,15,16,17,18,19,20,21 See General objections

This is what is attached:

Account Information Report
Account# xxxxxxxxxxxxx
Forwarder: CACH039/Washington Mutual Bank-CC
Acct# xxxxxxxxxxxxxx
Original Creditor: WAMU?PROVIDIAN BANK
Debt type: CC
Status: Returned to Collector
Assigned to : PRELEGAL 70 WIP# 0 Days left 0
Financial
Placement 06/02/2008 $2040.95
Last payment: $0.00
Rm. Pl. Amt. $2040.95
Interest: $368.16
Attorney $0.00
Court $0.00
Misc $0.00
Balance $2409.11

Then it list all my personal info, name address, four digits of SS, DOB

Debt
Service provided Credit Card
Last payment date 11/12/2007 $46.00

This is what I sent to them for my Request for admissions and production of Documents.
INTERROGATORIES

Interrogatory No. 1
Is CACH LLC the direct assignee of Wamu/Providian Bank? Or, is CACH LLC an assignee of an assignee? If there are additional assignees, identify each assignee, their business address, and telephone number.

Interrogatory No. 2
Identify when the alleged account was originally opened by the defendant and was subsequently charged off by Wamu/Providian Bank .

Interrogatory No. 3
Identify the person or persons answering these interrogatories. Include their business address, business phone number, and title within the Plaintiff???s Organization.

Interrogatory No. 4
Please provide the following information for each person known to the Plaintiff who has knowledge of facts relevant to this case, including but not limited to all persons interviewed by you, by your counsel, or by any person cooperating with you in the this action, giving a brief description thereof, for each person you may call as a witness in this case.
1. Name, address, and telephone number.
2. Place of Employment
3. Relation to the Plaintiff
4. The subjects and substance of the testimony the witness will give; and whether the witness is to be tendered as an expert witness.

Interrogatory No. 5
Please provide the following information.
1. Your Full Name
2. Your Full Business Name
3. Your Business Purpose (e.g. Creditor, Lender, Collection Agency, etc.)
4. Form of Business Organization (e.g. corporation, partnership, LLC, sole proprietorship, etc.)
Interrogatory No. 6
In regards to the contract or agreement alleged in this action, please state the following:
1. Terms of the Contract or Agreement:
2. Credit Limit Amount Financed in the Alleged Contract or Agreement:
3. Date and Monetary value of any valuable consideration received on the contract or agreement:
4. Date and Monetary value of any payments or credits alleged to be executed on the contract or agreement:

Interrogatory No. 7
Please provide the following information for each person who has had any involvement in any manner in any efforts on your behalf to collect or attempt to collect any debt (s) purportedly owing by Defendant.
1. His/Her Position
2. His/Her work address, telephone numbers
3. Nature and purpose of his/her involvement.

Interrogatory No. 8
Identify the persons or entities, regarding any debt(s), which you have attempted to collect from Defendant, identify all documents related or relevant to your contractual agreement(s) (Servicing, Assignment(s), etc.), or other business relationships with said persons or entities.

Interrogatory No. 9
Plaintiff or Attorney. Please Identify each person who has had any contact or communication on your behalf regarding Defendant???s purported debt(s), state when, how, where, and with whom said contact or communication occurred and in detail and with particularity the substance thereof.

Interrogatory No. 10
Attorney. Describe all collection activities, which you were authorized to perform for CACH LLC , and identify the terms of the agreement between CACH LLC and you pursuant to which you sought to collect this account.

Interrogatory No. 11
Describe procedure and policy with respect to the Maintenance, preservation, and destruction of documents, stating in your Answer whether any documents or things relating to any information Requested in these interrogatories, or related in any way to this lawsuit, have ever been destroyed or are no longer in your custody. For each such document, please identify the document, how, when and why each document was destroyed or otherwise left your control, the identity of any person who participated in any way in the destruction and/or action for destroying the document or to transfer it out of your control or custody; and if the document still exists, identify the person now having control or custody of the document.

Interrogatory No. 12
What document states in writing in support of your Complaint that the Defendant is indebted to pay the Plaintiff and when was this agreed statement in writing entered into?

Interrogatory No. 13
On what date did the defendant become indebted to the plaintiff for $2,040.95 plus any accrued interest?

Interrogatory No. 14
Identify all witnesses with evidence in support of your Complaint that the Defendant, entered into a contract and is indebted to the Plaintiff.

Interrogatory No. 15
State all actions taken to verify the accuracy and completeness of the accounts reported and state your procedures designed to assure the maximum possible accuracy of the information reported by you.

Interrogatory No. 16
What is the date that the defendant allegedly defaulted on the original account?

Interrogatory No. 17
What was the status of the alleged contract/account when acquired.

Interrogatory No. 18
What credit card purchases and/or cash advances were made on this account? When where they made?

Interrogatory No. 19
Please identify and describe each exhibit you will use in the trial of Cause No. CV-09-89.

Interrogatory No. 20
State fully, completely and at length the factual basis of each defense which you now assert or intend to assert in this action.

Interrogatory No. 21
As to each defense set out in response to Interrogatory Twenty (20), above, state the following as to notification to Defendant of such defenses; (a) the date or dates when notification was given; ( the manner in which notification was given; and ?? the specific party or parties to whom notification was given.

Interrogatory No. 22
How much was this account purchased for from Wamu/Providian Bank?

Interrogatory No. 23
Do you have the Actual Contract between the Defendant and Wamu/Providian Bank? And do you have the Assignment Agreement between Wamu/Providian Bank and CACH, LLC?

REQUESTS TO ADMIT FACTS
The Defendant requests that the Plaintiff answer the following requests to admit facts pursuant to, and in accordance with, Arkansas Rules of Civil Procedure 36. If the Plaintiff objects to any requested admission, the reason therefore shall be stated. The Plaintiff's answer shall specifically admit or deny the requested admission, or set forth in detail the reasons why the Plaintiff cannot truthfully admit or deny the requested admission. A denial shall fairly meet the substance of the requested admission, and when good faith requires that the Plaintiff qualify an answer or deny only in part of the matter of which an admission is requested, the Plaintiff shall specify so much of it as is true and qualify or deny the remainder, again detailing the specificity of the denial of the part thereof.
Fact No. 1
Please admit that you were not assigned Wamu/Providian Bank obligations under the purchase agreement.

Fact No. 2
Please admit that you do not have the original or a copy of an assignment between you and Wamu/Providian Bank .


Fact No. 3
Please admit that there was no written agreement, signed by Defendant, between Defendant and Wamu/Providian Bank.

Fact No. 4
Please Admit that there is no written agreement between CACH, LLC and the Defendant.

Fact No. 5
Please admit that the defendant is authorized to pay the Original Creditor/Lender until he receives notification of assignment of rights to payment, and that payment is to be made to the assignee.

Fact No. 6
Please admit that you did not send the defendant any notification of assignment of the account or assignment of rights.

Fact No. 7
Please admit that as of the date you drafted your Complaint, you had no evidence admissible at trial that proves Defendant owes the debt.

Fact No. 8
Please admit that CACH, LLC are considered Debt collectors under the Fair Debt Collection Practices Act.

Fact No. 9
Please admit that you are barred under the Fair Debt Collection Practices Act ?? 1692 f(1) from collecting interest on any amount not authorized by the agreement creating the debt or permitted by law.

Fact No. 10
Please admit that you do not have the agreement to claim the amount(s) submitted in the complaint.

Fact No 11
Please admit that you do not have a copy of or the original Cardholder Agreement.

Fact No 12
Please admit that you did not transfer your alleged assignment rights over to The McHughes Law Firm, LLC in order for them to collect your alleged debt.

Fact No. 13
Please admit that The McHughes Law Firm, LLC is the real party in interest.

Fact No. 14
Please admit that if you did purchase the alleged account it was in default.

Fact No. 15
Please Admit that if this assignment is proven by you it was purchased for less than the amount submitted in your complaint.


Fact No. 16
Admit that no notification of attempt to collect on this debt was sent to the following address by CACH, LLC: 166 Ginger Road, Scotland, AR 72141

Fact No. 17
Please admit that you cannot provide documents proving CACH, LLC owns this debt.

DOCUMENTS TO BE PRODUCED
1. Please provide the actual credit card contract upon which your Complaint is based on.
2. Please provide a contract, agreement, assignment, or other means of demonstrating that the Plaintiff has the authority and was legally entitled to collect on the alleged debt.
3. Please furnish reasonable proof, such as an original, or copies of the assignment agreement or assignment agreements, transferring the alleged contract and/or account in question from Wamu/Providian Bank over to CACH, LLC to show an Assignment has been made and that CACH, LLC are the real party in interest.
4. Please provide a copy of the Assignment between CACH, LLC and Wamu/Providian Bank.
5. Please evidence proof of the Defendant???s alleged debt to Plaintiff, including specifically the alleged contract, between the plaintiff and defendant or any other instrument constructed solely for the purpose of creating a loan agreement between the Plaintiff and Defendant bearing Defendants signature and/or Please Produce the contract that legally requires the Defendant to pay the amount entered into complaint.
6. Please provide the original or copy of the account agreement that states interest rate, grace period, finance charge, assignment, and specifically the State Laws that the agreement and account are governed plus other important facts.
7. Please provide copies of the amount paid and/or the consideration due for the alleged contract/ account.
8. Please Provide an Itemized account of all transactions mentioned in Interrogatory Number Eighteen (18).
9. Provide the Record of Assignment that displays the information in Interrogatory No. 22.
10. Please provide all copies of manuals, procedures, and protocols used by Plaintiff regarding communication and regarding purchased debt.
11. Please evidence authorization of Plaintiff to do business, create loans, issue or extend credit, collect debts and/or operate in the State where the Plaintiff conducts their business.
12. Please evidence authorization of Plaintiff & Attorney to do business, create loans, issue or extend credit, collect debts and/or operate as a financial business in the State of Arkansas.
13. Please provide a document or documents(s) that proves you did send the defendant a notification of assignment of the account or assignment of rights.
14. Please attach any and all notices sent to Defendant by Plaintiff in regards to this account demanding payment.
15. Please attach copies of all statements generated while this alleged account was open with Plaintiff.
16. Please attach a complete and accurate history of the interest charged on this alleged account with Plaintiff. Show the exact dates those interest rates changed and list the various rates that were charged during the this debt and the exact method of amortization.
17. Please attach any and all notices sent to Defendant by Plaintiff announcing changes in interest, fees or penalties and/or the terms of this alleged debt.
18. Identify each Credit Reporting Agency (credit bureau) to which the Plaintiff reported defendant???s debt and the dates of each such report.
19. Please provide the original dunning letter that was sent to Defendant.
20. Please attach any and all notices sent to Defendant by Plaintiff in regards to account announcing transfer and/or assignment of credit card account from plaintiff to any collection agency or collection attorney.
21. Please attach a copy of the agreement with Plaintiff that grants The McHughes Law Firm,LLC Attorney(s) the authority to collect this alleged debt.

Sorry for the double post. Idon't know how to remove it. Thanks!