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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

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the time allowed by California Rules of Civil Procedure 2033.250 will result in admission of the following requests per California Rules of Civil Procedure 2033.280. 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 2033.280. (b) Person includes natural persons, corporations, partnerships, associations, or any type of entity, and agents, servants, employees, and representatives thereof. (c ) The debt means the alleged debt or debts that is/are the subject of this lawsuit. (d) The account means any alleged account or accounts that is/are related to the debt. (e) The term identify, when used in reference to an individual person or business entity means to state his, her, or its full name together with any addresses, e-mail addresses, and phone numbers known. When used in reference to a document, identify means to state (in summary fashion) the substance of the document, the name of the person who prepared the document, and the date the document was generated or signed, and by whom. (f) The term document means any writing or record of any type and description, and any device or medium on which or through which information of any type can be transmitted, recorded, or preserved. The term document also means a copy, if the original is not in your possession, custody, or control, and every copy of the document that is not an identical duplicate of the original or other copies. (g) You, in these requests refers to Plaintiff, and any employees, persons acting at the direction of or on behalf of the Plaintiff. agents, or other

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Requests for Admissions

Pursuant to Rule 2033.250 & 2033.280 of the California Rules of Civil Procedure (C.R.C.P.), the following statements are deemed admitted unless you respond in writing within thirty (30) days with a proper denial or objection.

1. Credit card attorney are debt collectors. Admit Deny

2. Credit card attorney are collecting the alleged debt on behalf of ZWICKER AND ASSOCIATES, P.C. Admit Deny

3. There is no written agreement between the Plaintiff and the Defendant. Admit Deny

4. There is no written agreement between the Credit card attorney and the Defendant. Admit Deny

5. The alleged Defendant has not consented to any assignment of the alleged account. Admit Deny

6. Credit card attorney was not assigned the original creditor's obligations under the alleged credit agreement. Admit Deny

7. Plaintiff is not the real party at interest. Admit Deny

8. Credit card attorney is not the real party at interest.

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Admit

Deny

9. The Plaintiff has charged off the alleged debt? Admit Deny

10. The Plaintiff has filed a claim for the loss of the alleged debt? Admit Deny

11. 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

14. Defendant requested validation of the alleged debt before prior to Plaintiffs complaint. Admit Deny

15. Plaintiff did not send validation requested to Defendant prior to the Plaintiffs complaint being filed. Admit Deny

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I hereby certify, under the penalties of perjury, that the foregoing answers are true, correct, and complete. ___________________________________ Representative for Credit card attorney

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