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Plantiff's initial rule 26.1 disclosure statement.

Asked Jul 6, 2012, 07:15 PM —
Factual Basis of Plantiff. Plantiff is current assignee of the contract between def. and plaintiff. Defendant defaulted on her obligations under the contract leaving an ouutstanding bal. upaid and due. Original creditor charged off acct. Account was sold at a commercially reasonable sale leaving a deficiency balance due and owing. Plaintiff puchased the defendants contract for xxx dollars. 3rd party submitted docs. but they have no identifying numbers or prove they even go to my cc acct.
What would be my legal response and legal theory behind it.



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