Help me please! I need 2 responed by Friday!
Date: Tue, 06/01/2010 - 07:50
I recieved a civil summons for a HSBC credit card in Sept 2009. I answered the summons with a request to validate debt etc with the help of CMS in Sept 2009. Now in May 2010, I recieved a Plaintiff's response for Production of Documents. I got an email today stating that CMS is no longer able to help me. The owner of CMS was told by the courts in his state that he is no longer to help his clients with court documents. I do not know what I need to do now. I cannot afford to hire a lawyer to help me. Please help me!
This is what I recieved from them:
STATE OF NORTH CAROLINA
COUNTY OF UNION
MAIN STREET ACQUISITION CORP.,
Plaintiff
vs.
IN THE GENERAL COURT OF JUSTICE
DISTRICT COURT DIVISION
09CvD3594
Defendant
PLAINTIFF'S FIRST
REQUEST FOR PRODUCTION
OF DOCUMENTS
To:
NOW COMES the plaintiff herein, Main Street Acquisition Corp., and pursuant to the
provisions of G.S. § 1A-1, Rule 34, herewith serves upon you the following Request for
Production of Documents. You are requested to respond to, for the purposes of this action only,
the following within thirty (30) days after service hereof.
1. Any and all copies of documents or correspondence from the Defendant to Plaintiffs
predecessors) in interest regarding the HSBC Bank Nevada, N.A. charge account bearing the
account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
2. Any and all copies of documents or correspondence from Plaintiffs predecessor(s) in
interest to the Defendant regarding the HSBC Bank Nevada, N.A. charge account bearing the
account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
3. Any and all copies of documents or correspondence from the Defendant to the
Plaintiff regarding the HSBC Bank Nevada, N.A. charge account bearing the account number
ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
4. Any and all copies of documents or correspondence from the Plaintiff to the
Defendant regarding the HSBC Bank Nevada, N.A. charge account bearing the account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
5. Copies of all payments made by the Defendant to Plaintiffs predecessor(s) in interest
regarding the HSBC Bank Nevada, N.A. charge account bearing the account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
6. Copies of all payments made by the Defendant to Plaintiff regarding the HSBC Bank
Nevada, N.A. charge account bearing the account number ending in the last four (4) digits of
XXXX-XXXX-XXXX-3 810.
7. Copies of all monthly account statements, cancelled checks, certificates of payment
and debit transactions for any and all financial and lending institutions with which the Defendant
had a checking account from December 1, 2007 to December 31, 2008.
8. Copies of all monthly account statements, cancelled checks, certificates of payment
and debit transactions for any and all financial and lending institutions with which the Defendant
had a savings account from December 1, 2007 to December 31, 2008.
9. A copy of the Defendant's credit report dated no earlier than September 16, 2009,
from one of the three leading credit-reporting agencies: TransUnion, Equifax, or Experian.
This the 4th day of May, 2010.
By:
SESSOMS & ROGERS, P.A.
Pedro^Zabala, II
Attorney for Plaintiff
3326 Durham-Chapel Hill Blvd., Suite A-200
P.O. Box 52508
Durham, North Carolina 27717
Telephone: (919)688-1000
CERTIFICATE OF SERVICE
This is to certify that, pursuant to Rule 5(b) of the North Carolina Rules of Civil
Procedure, the foregoing Plaintiffs Request for Production of Documents was this day served
upon the defendant in this action by mailing a copy thereof, postage prepaid, to the defendant, as
follows:
This the 7 day of rfffa// , 2010.
r
SESSOMS & ROGERS, P.A.
By:_
Pedro J. Zabala, II
Attorney for Plaintiff
3326 Durham-Chapel Hill Blvd., Suite A-200
P.O. Box 52508
Durham, North Carolina 27717
Telephone: (919)688-1000
Is this what my response should look like? Also unsure if the first paragraph is needed or how I should word it! And Im sure this needs to be changed to NC (Mass.R.Civ.P. 26(e).)
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
COUNTY OF UNION DISTRICT COURT DIVISION
09 CvD 3594
MAIN STREET ACQUISITION CORP.,
Plaintiff DEFENDANT’S RESPONSE
vs. TO PLANTIFFS
REQUEST FOR PRODUCTION
OF DOCUMENTS
To:
NOW COMES the plaintiff herein, Main Street Acquisition Corp., and pursuant to the
provisions of G.S. § 1A-1, Rule 34, herewith serves upon you the following Request for
Production of Documents. You are requested to respond to, for the purposes of this action only,
the following within thirty (30) days after service hereof.
1. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
2. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
3. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
4. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
5. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
6. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
7. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
8. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
9. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
This the 27 day of May, 2010.
By:
CERTIFICATE OF SERVICE
This is to certify that, pursuant to Rule 5(b) of the North Carolina Rules of Civil
Procedure, the foregoing Plaintiffs Request for Production of Documents was this day served
upon the defendant in this action by mailing a copy thereof, postage prepaid, to the defendant, as
follows:
This is what I recieved from them:
STATE OF NORTH CAROLINA
COUNTY OF UNION
MAIN STREET ACQUISITION CORP.,
Plaintiff
vs.
IN THE GENERAL COURT OF JUSTICE
DISTRICT COURT DIVISION
09CvD3594
Defendant
PLAINTIFF'S FIRST
REQUEST FOR PRODUCTION
OF DOCUMENTS
To:
NOW COMES the plaintiff herein, Main Street Acquisition Corp., and pursuant to the
provisions of G.S. § 1A-1, Rule 34, herewith serves upon you the following Request for
Production of Documents. You are requested to respond to, for the purposes of this action only,
the following within thirty (30) days after service hereof.
1. Any and all copies of documents or correspondence from the Defendant to Plaintiffs
predecessors) in interest regarding the HSBC Bank Nevada, N.A. charge account bearing the
account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
2. Any and all copies of documents or correspondence from Plaintiffs predecessor(s) in
interest to the Defendant regarding the HSBC Bank Nevada, N.A. charge account bearing the
account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
3. Any and all copies of documents or correspondence from the Defendant to the
Plaintiff regarding the HSBC Bank Nevada, N.A. charge account bearing the account number
ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
4. Any and all copies of documents or correspondence from the Plaintiff to the
Defendant regarding the HSBC Bank Nevada, N.A. charge account bearing the account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
5. Copies of all payments made by the Defendant to Plaintiffs predecessor(s) in interest
regarding the HSBC Bank Nevada, N.A. charge account bearing the account number ending in the last four (4) digits of XXXX-XXXX-XXXX-3810.
6. Copies of all payments made by the Defendant to Plaintiff regarding the HSBC Bank
Nevada, N.A. charge account bearing the account number ending in the last four (4) digits of
XXXX-XXXX-XXXX-3 810.
7. Copies of all monthly account statements, cancelled checks, certificates of payment
and debit transactions for any and all financial and lending institutions with which the Defendant
had a checking account from December 1, 2007 to December 31, 2008.
8. Copies of all monthly account statements, cancelled checks, certificates of payment
and debit transactions for any and all financial and lending institutions with which the Defendant
had a savings account from December 1, 2007 to December 31, 2008.
9. A copy of the Defendant's credit report dated no earlier than September 16, 2009,
from one of the three leading credit-reporting agencies: TransUnion, Equifax, or Experian.
This the 4th day of May, 2010.
By:
SESSOMS & ROGERS, P.A.
Pedro^Zabala, II
Attorney for Plaintiff
3326 Durham-Chapel Hill Blvd., Suite A-200
P.O. Box 52508
Durham, North Carolina 27717
Telephone: (919)688-1000
CERTIFICATE OF SERVICE
This is to certify that, pursuant to Rule 5(b) of the North Carolina Rules of Civil
Procedure, the foregoing Plaintiffs Request for Production of Documents was this day served
upon the defendant in this action by mailing a copy thereof, postage prepaid, to the defendant, as
follows:
This the 7 day of rfffa// , 2010.
r
SESSOMS & ROGERS, P.A.
By:_
Pedro J. Zabala, II
Attorney for Plaintiff
3326 Durham-Chapel Hill Blvd., Suite A-200
P.O. Box 52508
Durham, North Carolina 27717
Telephone: (919)688-1000
Is this what my response should look like? Also unsure if the first paragraph is needed or how I should word it! And Im sure this needs to be changed to NC (Mass.R.Civ.P. 26(e).)
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
COUNTY OF UNION DISTRICT COURT DIVISION
09 CvD 3594
MAIN STREET ACQUISITION CORP.,
Plaintiff DEFENDANT’S RESPONSE
vs. TO PLANTIFFS
REQUEST FOR PRODUCTION
OF DOCUMENTS
To:
NOW COMES the plaintiff herein, Main Street Acquisition Corp., and pursuant to the
provisions of G.S. § 1A-1, Rule 34, herewith serves upon you the following Request for
Production of Documents. You are requested to respond to, for the purposes of this action only,
the following within thirty (30) days after service hereof.
1. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
2. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
3. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
4. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
5. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
6. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
7. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
8. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
9. Defendant is unaware of any such documents. Defendant will seasonably supplement this response pursuant to Mass.R.Civ.P. 26(e).
This the 27 day of May, 2010.
By:
CERTIFICATE OF SERVICE
This is to certify that, pursuant to Rule 5(b) of the North Carolina Rules of Civil
Procedure, the foregoing Plaintiffs Request for Production of Documents was this day served
upon the defendant in this action by mailing a copy thereof, postage prepaid, to the defendant, as
follows:
I would not use anything from another state. Try and find a pro
I would not use anything from another state. Try and find a proper discovery response from NC because the statutes will be different, and the court rules are different. The best thing to do, rather than say you'll seasonally supplement a statement is to take all the time you're given to respond and produce the documents, or if you can't get them by the deadline ask the judge for more time.
If you need legal advice on NC law, a good place to get it for free from a NC lawyer is www.lawguru.com.
