I filed a request for prod of documents with debt collector on 9/27/07, and let me note that it has gonecompletely unanswered. Anyway, their attorney sent me one.
They want to know:
1. provide all agreements etc that evidence transaction by you w/ plaintiff. (I don't even know of having an acct with plaintiff citibank, duh how can I give them evidence of it?)
2. All receipts, cancelled checks, etc evidence of payments

OK this is where I'm confused:
3. Any and all letters notes, memoranda, or other written correspondance or records of any oral communication by you or by others on your behalf with plaintiff.
* Do I need to list what I've sent to the plaintiff, which would be request for validation, sworn denial of debt, and request for prod. of documents?

4. Any and all documents, letters, papers, or writing which you intend to use to support any defense to plaintiff's claim or which you intend to offer as evidence at trial.
* What would these be?

5. Any and all statements referred to in your answers to interrogatories
*which I haven't answered yet

Oh yeah. And how come I submitted a request for production of documents to them and it's gone unanswered, but they getto have my answers?