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IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA
M IDLAND FUNDING LLC CASE NO. COWE 11-XXXas successor in
interest to CIVIL ACTION SU MM ONS Bank of America
Plaintiff,
Vs.
XXXXXXXX
Defendant(s)
______________________________/
RESPONSE TO PLAINTIFFS REQUEST TO PRODUCTION OF DOCU M
ENTSEXHIBIT D
Comes now, Defendant XXXXXXX pro se, and files respond to
Plaintiffs Request for Production of Documents, as set forth in the
following manner:
GENERAL OBJECTIONS
Defendant generally objects and responds to the Document Request
on the grounds setforth below. All general objections shall be
deemed to be continuing and shall be construed assupplementing each
specific objection and/or response to the Document Requests.
A. Defendant objects generally to the Document Request is not
intended and should not be construed to the extent they assume
facts that are inaccurate, argumentative anddefective in form.
B. Defendant objects generally to the Document Request to the
extent they seek documents not in its possession, custody or
control.
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1. Defendant objects as the Plaintiffs request for Documents No.
1 as it assumesthere is an account being sued upon where no valid
account has been identifiedyet by the Plaintiff. The defendant
cannot provide what is requested.
2. See Attached.
3. Defendant objects as the Plaintiffs request for Documents No.
3 is overbroad andunduly burdensome to the extent it seeks document
or records that are not withinthe current knowledge, possession,
custody or control of the Defendant. ThePlaintiff claims they are
the Assignee of the alleged account therefore thesedocuments should
be more readily or accessible to Plaintiff from its own files,
from documents already in Plaintiffs possession. The defendant
has nodocuments to provide this request.
4. Defendant objects as the Plaintiffs request for Documents No.
4 on the groundsthat it is burdensome, seeing it is requesting
documents in regard to the contractsued upon, where no contract as
of yet has been identified by the Plaintiff or their attorneys. The
Defendant has nothing is his possession to provide.
5. Defendant objects the extent that it requires defendant to
respond by supplyinginformation is already in the possession of or
equally available to Plaintiff.Defendant is still in the process of
gathering evidence for trial and will providePlaintiff with
information responsive to this request as soon as it
becomesavailable.
6. Defendant objects the extent that it requires defendant to
respond by supplyinginformation is already in the possession of or
equally available to Plaintiff.Defendant is still in the process of
gathering evidence for trial and will providePlaintiff with
information responsive to this request as soon as it
becomesavailable.
7. Defendant objects the extent that it requires defendant to
respond by supplyinginformation is already in the possession of or
equally available to Plaintiff.Defendant is still in the process of
gathering evidence for trial and will provide
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Plaintiff with information responsive to this request as soon as
it becomesavailable.
8. Defendant objects the extent that it requires defendant to
respond by supplyinginformation is already in the possession of or
equally available to Plaintiff.Defendant is still in the process of
gathering evidence for trial and will providePlaintiff with
information responsive to this request as soon as it
becomesavailable.
9. See attached Exhibit B, C.
10. See attached Exhibit B, C .
11. See attached Exhibit B, C.
12. Defendant objects as the Plaintiffs request for Documents
No. 12 as it assumesthere is an account being sued upon where no
valid account has been identifiedyet by the Plaintiff. The
defendant cannot provide what is requested.
13. Defendant objects as the Plaintiffs request for Documents
No. 13 as it assumesthere is an account being sued upon where no
valid account has been identified
yet by the Plaintiff. The defendant cannot provide what is
requested.
14. Defendant objects as the Plaintiffs request for Documents
No. 14 as it assumesthere is an account being sued upon where no
valid account has been identifiedyet by the Plaintiff. The
defendant cannot provide what is requested.
Defendant,
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