Sample request for discovery

1. Identify your company and state all names by which you have been known. 2. If you intend to rely upon any documents or other tangible things to support a position that you have taken or intend to take in the action, including a claim for damages, provide a brief description, by category and location, of all such documents and other tangible things, and identify all persons having possession, custody, or control of them (Stand General Interrogatory No. 3). 3. Identify each person, other than a person intended to be called as an expert witness at trial, having discoverable information that tends to support a position that you have taken or intend to take in this action, including any claim for damages, and state all the subject matter of the information possessed by that person. (Stand General Interrogatory No. 1). 4. Identify all persons who are expected to testify on your behalf as expert witnesses at trial and state the subject matter about which each such person is expected to testify, the substance of the facts and opinions to which each person is expected to testify and a summary of the grounds for each such opinion. 5. State with particularity all facts upon which you rely to support the calculation of the debt: a. How did you determine the amount of the original debt? Do you have a payment history to support it? b. How were interest rates calculated and did they meet Florida limitations? c. Did the original creditor receive a tax break for the charge-off for the IRS? How much? d. How were late fees determined? e. How were court fees determined? 6. State with particularity all facts upon which you rely to support your allegations that the Defendant owes the debt. Include a copy of the original contract with the original creditor. 7. State with particularity, all reasons that the Plaintiff is legally able to collect the debt. Include a copy of the letter of assignment or sale of the debt. 8. Attach your Answers to these Interrogatories the following documents: any written instrument upon which your claim is founded. any statements concerning the action or its subject matter previously made by the Defendant whether a written statement, signed or otherwise adopted or approved by that party, or a stenographic, mechanical, electrical, or other recording, or a transcription thereof, that is a substantially verbatim recital of an oral statement made by the Defendant and contemporaneously recorded; and any written report, whether acquired or developed in anticipation of litigation or for trial, made by an expert whom you expect to call as an expert witness at trial.