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Name and Address All Rights Reserved In Common Law

FIRST REQUEST FOR ADMISSIONS

Plaintiff, Plaintiff,

) Case No. ) ) DEFENDANT'S FIRST REQUEST FOR

vs.

) ADMISSIONS )

Defendant, Defendant,

) ) )

To: Plaintiff, XXXXXXXXXXXXXXXXX

Introduction Defendant requests Plaintiff to answer the following first request for admissions within thirty (30) days of service, to Plaintiff c/o Address. These discovery requests shall be deemed continuing as to require supplementary responses if Plaintiff obtains further information between the time responses are served and the time of trial.

Instructions (a) Answers to the following responses to the following requests for admissions are due within 30 days of service. Failure to serve a written answer or objection within

[DEFENDANT'S FIRST REQUEST FOR ADMISSIONS] - 1

when used in reference to an individual person or business entity means to state his. her. partnerships. or preserved.250 will result in admission of the following requests per California Rules of Civil Procedure 2033. When used in reference to a document. or control. persons acting at the direction of or on behalf of the Plaintiff. and phone numbers known. recorded. employees.2 . or other [DEFENDANT'S FIRST REQUEST FOR ADMISSIONS] . identify means to state (in summary fashion) the substance of the document. (g) You.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the time allowed by California Rules of Civil Procedure 2033. (b) Person includes natural persons. (e) The term identify. the name of the person who prepared the document. agents. corporations. if the original is not in your possession. (f) The term document means any writing or record of any type and description. Any admission for which no response is noted in the space provided for a response shall be deemed admitted under California Rules of Civil Procedure 2033. The term document also means a copy. or any type of entity. and any employees. e-mail addresses. or its full name together with any addresses. servants. and any device or medium on which or through which information of any type can be transmitted. and the date the document was generated or signed. (c ) The debt means the alleged debt or debts that is/are the subject of this lawsuit.280. in these requests refers to Plaintiff. and representatives thereof. and agents. and every copy of the document that is not an identical duplicate of the original or other copies. custody.280. and by whom. associations. (d) The account means any alleged account or accounts that is/are related to the debt.

Admit Deny 7. Plaintiff is not the real party at interest. The alleged Defendant has not consented to any assignment of the alleged account. Admit Deny 6. P. There is no written agreement between the Plaintiff and the Defendant. Credit card attorney are collecting the alleged debt on behalf of ZWICKER AND ASSOCIATES. Credit card attorney is not the real party at interest. Admit Deny 8.C. 1. Credit card attorney are debt collectors. Admit Deny 3. the following statements are deemed admitted unless you respond in writing within thirty (30) days with a proper denial or objection.P.250 & 2033. [DEFENDANT'S FIRST REQUEST FOR ADMISSIONS] .3 .). There is no written agreement between the Credit card attorney and the Defendant. Admit Deny 5.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Requests for Admissions Pursuant to Rule 2033.R. Admit Deny 4.C.280 of the California Rules of Civil Procedure (C. Credit card attorney was not assigned the original creditor's obligations under the alleged credit agreement. Admit Deny 2.

The Plaintiff has charged off the alleged debt? Admit Deny 10.4 . Plaintiff did not send validation requested to Defendant prior to the Plaintiffs complaint being filed. The Plaintiff has been paid from the filed a claim for the loss of the alleged debt? Admit Deny 12. Plaintiff does not have a contract signed by Defendant with a bona fide signature? Admit Deny 13. Plaintiff does not have personal knowledge of the validity of a signature on the alleged agreement. Admit Deny 15.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Admit Deny 9. Admit Deny 14. The Plaintiff has filed a claim for the loss of the alleged debt? Admit Deny 11. Admit Deny [DEFENDANT'S FIRST REQUEST FOR ADMISSIONS] . Defendant requested validation of the alleged debt before prior to Plaintiffs complaint.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I hereby certify. that the foregoing answers are true. and complete. ___________________________________ Representative for Credit card attorney [DEFENDANT'S FIRST REQUEST FOR ADMISSIONS] .5 . correct. under the penalties of perjury.