I need some help with filing the disclosure statement. I am going to list what I put in my answer as well as the disclosure statement from JDB.

My answer:

1. ADMIT - I am who they think I am & live where they think I do
2. DENY - Defendant does not have information sufficient to admit or deny the matter at the time.
3. DENY - This request calls for admission of matter defendant has denied and thus is improper.

Affirmative defenses:
1. Lack of Privity - No relationship exists between the collection agency and me
2. Failed to state the basis of the lawsuit: They did not cite an actual state law which was violated.
3. Statue of frauds - No contract exists as proof
4. Implicit in the right to self representation it is the obligation on the part of the court to make reasonable allowances to protect ProSe litigants from inadvertent forfeiture of important rights because of their lack of legal training. Also, the Court's duty is eve broader in the case of a Pro Se defendant who finds himself in court against her will with little time to learn the intricacies of civil procedure and law - See 28 USCA 1654.

Their disclosure statement:
The undersigned party, pursuant to Rule 26.1(b)(1) ARCP Discloses the following and certifies that such disclosure includes all information in his possession, custody and control, as well as any information which can be determined, learned or obtained by reasonable investigation:
1. Factual Basis for each claim/defense: That Defendant, entered into a credit card agreement with Plaintiff/Plaintiff's assignor, Midland Funding LLC.
2. A description of the damage(s) and copies of any exhibits that show how you calculated the dollar value of the damages. BRING A COPY OF THESE DOCUMENTS/EXHIBITS TO ANY PRETRIAL CONFERENCE WHICH MAY BE SCHEDULED: That the damages are computed by debts and credits to the credit account of Defendant.
3. The legal theory upon which each claim/defense is based: Plaintiff/Plaintiff's Assignor and Defendant entered into a contract. Defendant breach of contract by failure to pay as agreed. Plaintiff/Plaintiff's Assignor is entitled to payment of the outstanding balance, interest, attorney fees and costs due to Defendant breach under the terms of the contract.
4. On a separate page entitle "list of witnesses' and made apart of this Disclosure, list the names, addresses and telephone numbers of any witnesses whom the undersigned party expects to call at trial. (Include a brief summary of their testimony)
5. On a separate page entitled 'list of documents and other information'
A. List the documents or evidence which would be available for review by the Court which supports the claim(s) of the undersigned party. BRING A COPY OF THESE AND DESCRIPTION OF THE EVIDENCE TO ANY PRETRIAL CONFERENCE WHICH MAY BE SCHEDULED.
B. Any other information, documents, or witnesses of which the undersigned party has knowledge, or that a reasonable person would recognize as leading to the discovery of such knowledge pertaining to this matter is outlined on a separate page and made a part of this disclosure.

SO... what do I file as my own disclosure?
Do I file Request for Production of Documents at the same time?
Do I file my own interrogatories and request for admissions?

We have been set for a mediation next weds, the 18th. Of course the JDB has already sent me a letter giving me a last chance to settle before that. What should I expect at the mediation, and do I need to present anything at that time?

Most of all... I need to file my Disclosures ASAP... but don't know what to say. Can't find any samples anywhere. Anyone?

Change your answer in 1.I cannot admit or deny the alleged debt until the plaintiff provides a certified copy of the alleged debt, bearing a wet ink signature.

Delete number 2