I was served for a credit card debt that was not mine. I filed a response and sent the plaintiff as set of questions to answer, but he has not responded in over thirty days. I did respond to his interrogatories, I also sent him another list of formal interrogatories as well as a request for production of documents and admissions. The first was more than 30 days ago. The second set was only 14 days ago. Even though the first request was not structured as an interrogatory, it was my understanding that it was acceptable as a request for evidence. I filled both requests with the court. Do I have enough to file a motion to dismiss? And if so I am not sure how to structure it.