INTERROGATORIES AND ADMISSION REQUESTS

DEFINITIONS

The following words have the designated meanings:(A) “Account” means the indebtedness alleged in the Complaint.(B) “Default” has the same meaning as used by Plaintiff in the Paragraph 1 of the

Complaint.(C) “Finance charges” has the same meaning as “finance charge” under 15 U.S.C.

§ 1605.(D) “Natural Person” means a human being.(E) “Original Issuer” is the Person who opened the Account for Defendant.(F) “Person” means any entity and includes, without limitation, a Natural Person, sole

proprietorship, limited liability company, government or governmental subdivision, and any type of partnership, corporation, association, organization, institution, or firm.

(G) “Record” includes all recorded information which concern or relate to the Account, including “documents” as used in R. 4:18-1(a) and “writing” as used in Evid.R. 801(e).

(H) “You,” “your”, “yours”, “yourself” refers to the Plaintiff.

INTERROGATORIES1. State the names and addresses of all persons who have knowledge of any

facts relating to the case.

2. Identify all documents that may relate to this action, and attach copies of such document.

3. Attach a complete copy of any written records or documents that you have regarding defendant, along with a typed transcription of any handwritten records and documents.

4. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies.

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5. If you claim that the defendant made any admissions as to the subject matter of this lawsuit, state: (a) the date made; (b) the name of the person by whom made; (c) the name and address of the person to whom made; (d) where made; (e) the name and address of each person present at the time the admission was made; (f) the contents of the admission; and (g) if in writing, attach a copy.

6. If you or your representative and the defendant have had any oral communication concerning the subject matter of this lawsuit, state: (a) the date of the communication; (b) the name and address of each participant; (c) the name and address of each person present at the time of such communication; (d) where such communication took place; and (e) a summary of what was said by each party participating in the communication.

7. If you claim that the violation of any statute, rule, regulation or ordinance is a factor in this litigation, state the exact title and section.

8. Set forth a particular statement of the items of the claim, their amounts and dates, a calculation in figures of the amount of interest, the payments or credits, if any, and the net amount due.

9. What is the name and address of each person who owned the account after default?

10. What is the name and address of each broker who participated or facilitated the sale or assignment of the account after the account was in default?

11. Set forth a description sufficient to identify each record which reflects the sale or assignment of the account after the account was in default.

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12. Attach to your response to these Interrogatories a copy of each record identified in your response to Interrogatory #11 and, in the immediately following space, either state that all records are attached or identify which records are not attached.

13. Provide the name and address of each natural person who is competent to authenticate – within the meaning of Evid.R. 901 – each record identified in your response to Interrogatory #11. Defendant will accept, as fully responsive, the names and addresses of those natural persons who you might call as a witness at the time of trial to authenticate each record identified in your response to Interrogatory #11.

14. Provide the name and address of each natural person who is competent to testify as to any facts necessary to admit each record identified in your response to Interrogatory #11 into evidence under Evid.R. 803(c)(6). Defendant will accept, as fully responsive, the names and addresses of those natural persons who you might call as a witness at the time of trial to testify as to any facts necessary to admit each record identified in your response to Interrogatory #11 into evidence under Evid.R. 803(c)(6).

15. Set forth a description sufficient to identify all records in your possession concerning the account.

16. Attach to your response to these Interrogatories a copy of each record identified in your response to Interrogatory #15 and, in the immediately following space, either state that all records are attached or identify which records are not attached.

17. Provide the name and address of each natural person who is competent to authenticate – within the meaning of Evid.R. 901 – each record identified in your response to Interrogatory #15. Defendant will accept, as fully responsive, the names and addresses of those natural persons who you might call as a

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witness at the time of trial to authenticate each record identified in your response to Interrogatory #15.

18. Provide the name and address of each natural person who is competent to testify as to any facts necessary to admit each record identified in your response to Interrogatory #15 into evidence under Evid.R. 803(c)(6). Defendant will accept, as fully responsive, the names and addresses of those natural persons who you might call as a witness at the time of trial to testify as to any facts necessary to admit each record identified in your response to Interrogatory #15 into evidence under Evid.R. 803(c)(6).

19. What is the date the account was opened?

20. What is the date the account first went into default?

21. If you assert a claim for legal fees, attach your written retainer agreement with your attorney and indicate in the space below that the requested item is attached or state the reason why it is not attached.

22. Attach to your response to these Interrogatories a copy of each record reflecting all transactions and credits to the account and, in the immediately following space, either state that all records are attached or identify which records are not attached.

23. What is the amount of finance charges included in the amount claimed by Plaintiff in this action?

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24. Identify each individual you expect to call at trial as an expert witness and include the subject matter on which each person is expected to testify, the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion.

25. What is the full name, job title and work address of the natural person who certified the answers to these interrogatories on your behalf?

[END OF INTERROGATORIES]

RESPONDING PARTY’S CERTIFICATION TO ANSWERS TO INTERROGATORIES

I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are wilfully false, I am subject to punishment.

Dated: [Print Name and Title Below Signature]

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ADMISSION REQUESTS

1. Plaintiff has no personal knowledge as to the mailing by the original issuer to Defendant of any written agreement governing the account.___ADMIT ___DENY

2. Plaintiff has no personal knowledge as to the mailing by the original issuer to Defendant of any billing statement for the account.___ADMIT ___DENY

3. Plaintiff has no personal knowledge as to why the original issuer entered any transaction, debit, credit or charge on any billing statement for the account.___ADMIT ___DENY

4. Neither Plaintiff nor its attorney possesses a Sworn Statement executed by or on behalf of the Original Creditor which purports to authenticate the genuineness of any documents related to the account.___ADMIT ___DENY

5. Plaintiff’s right to acquire documents from the original issuer about the account is governed by the written agreement under which Plaintiff acquired the account.___ADMIT ___DENY

6. The account was securitized by the original issuer by transfer to a bankruptcy remote entity.___ADMIT ___DENY

7. The account arose primarily out of transactions in which the money, property, insurance or services which are the subject of the transactions are primarily for personal, family or household purposes. ___ADMIT ___DENY

8. Plaintiff has no claims against Defendant except those alleged in the Complaint. ___ADMIT ___DENY

9. Plaintiff does not have possession of and cannot obtain possession of Defendant’s application for the account.___ADMIT ___DENY

10. Plaintiff does not possess and cannot obtain possession of the written terms and conditions which governed the account at the time the account was opened. ___ADMIT ___DENY

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11. Plaintiff does not possess and cannot obtain possession of the written terms and conditions which governed the account at the time when the account first went into default.___ADMIT ___DENY

12. Plaintiff does not possess and cannot obtain possession of all of the account’s periodic billing statements. ___ADMIT ___DENY

13. Plaintiff does not possess and cannot obtain possession of the account’s periodic billing statements from a time when the account balance was equal to or less than zero. ___ADMIT ___DENY

14. Plaintiff does not possess and cannot obtain possession of any Sworn Statement which contains the Declarant’s original signature.___ADMIT ___DENY

15. Plaintiff does not possess and cannot obtain possession of any of the Truth in Lending Act disclosures made by the original issuer. ___ADMIT ___DENY

16. Finance charges on the account exceeded $250.00.___ADMIT ___DENY

17. Finance charges on the account exceeded $1,000.00.___ADMIT ___DENY

18. Finance charges on the account exceeded $2,000.00.___ADMIT ___DENY

19. Finance charges on the account exceeded $2,500.00.___ADMIT ___DENY

Signed by Responding Party’s (CHECK ONE) ____ authorized representative or ____ attorney:

Dated: [print name and title below signature]

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