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Sep 17, 2007, 05:04 PM
Sample of Discovery Notice
IN THE DISTRICT COURT OF MARYLAND FOR CECIL COUNTY
Alleged company name
Plaintiff CASE NO. 123456789
TO: Company name, Plaintiff
FROM: your name, Defendant
The Defendant, pursuant to Rule 3-421 of the Maryland Rules of Civil procedure, propounds the following Interrogatories, to be answered within fifteen (15) days after service of the same, subject to the following instructions.
(a) These interrogatories are continuing in character, so as to require you to file supplementary answers if you obtain further or different information before trial.
(b) “Identify” or “Identification” when used in reference to an individual person means to state his full name, business affiliation, present or last known home and/or business telephone number and present and/or last known residence address. “Identify” or “Identification” when used in reference to a document means to state the type of document (e.g. letter, memorandum, telegram, chart, etc.) or some other means of identifying it, the date, if any, its present location and the name and address of its custodian. If any such documents was, but is no longer, in your possession or subject to your control, state the disposition was made of it and the reason for such disposition.
( c) Unless otherwise indicated, these interrogatories, and all references to the “occurrence” refer to the time, place and circumstances mentioned or complained of in the pleadings.
(d) Where knowledge or information in the possession of a party is requested, such request includes knowledge of the party's agents, representatives and unless privileged, his or its attorney. When the answer is made by a corporate or partnership plaintiff, state the name and address and title of the person supplying the information and making the affidavit, and indicate the source of information
(e) The pronoun “you” refers to the party to whom these Interrogatories are addressed, and the persons mentioned in clause (d) above.
(f) All answer are to be under oath and true, correct and complete
Please answer the following Interrogatories:
1. State you full legal name, any aliases used now or in the past, occupation, home and business addresses, and social security number.
2. Provide certified copy of the of the alleged debt and provide complete account from the beginning of alleged account
3. Provide a letter stating the whether plaintiff has purchased the alleged debt and for what amount.
4. Provide documentation of the alleged payments to the alleged and account and how they were made
5. Provide copy of the original credit application, any and all income verification that was provide to Alleged account name for the credit application.
6. Identify all person who have given written or recorded statements concerning the subject matter of this actions, including the date of each statement, the identity of the person taking the statement, and the identity of the present custodian thereof.
7. If you intent to call any expert witnesses to testify at the trial of this case, state the name, address and field of expertise of each such expert and, if any such expert has submitted a written report, attach a copy of same to our Answers to Interrogatories.
8. State the date, time, place and exact content of each an every conversation which you or your agents, representatives or employees had with the defendant, its agents, representatives, servants and/or employees, in any way pertaining to the occurrences complained of in this lawsuit, identifying the persons or representatives acting on their behalf which spoke during each such conversation and their relationship to the parties, as well as all witness to each such conversation and their relationship to you or the defendant, if any.
9. If you will rely on any documents or photographs at the trial of this case, identify each such documents, as well as the person with custody of each such documents or a true copy thereof. If you will do so without Motion to Produce, kindly attach a legible photocopy of each such document to your Answers to Interrogatories.
10. States all avers to the your claim, setting forth all facts and the basis for each such aver.
City, state, zip