As many here know from my past posts I am being sued for an auto repo. I sent my demand for admissions to the plaintiff a week or more ago and today I got their demand for discovery.
Although I have 45 days from today to respond they only have 30 days to respond to my demands so I have them behind the old 8 ball time wise. In order to give an example of how to respond to admissions I have posted a link to my proposed responses to their demand for admissions on my google docs page. You can clisk on the link below and see how I plan to respond.
Of course, I will prepare a second set of admission demands which I plan to send to them tomorrow. Those will be based on their demands to me. Let them answer their own questions. (LOL) Well, to some extent at least. Then when we get close to the 45 day mark I'll file a motion for protective order from most of their questions. At the end of the 30 day mark I'll file motion to deem admitted anything they didn't admit. IF they don't answer at all then I'll just pick and choose between the list of 44 questions I sent them to have deemed admitted.
I may very well not win but I'm sure planning to give them some major headaches before it is all said and done. My responses need some quotes from Oklahoma Statutes and from civil rules of procedure yet but I've got plenty of time to get those located and quoted.
What I have posted on my google docs is just the admissions section. They also sent demand for interrogatories and production of documents which I will also respond to and post my responses later.
Please don't think I am trying to give legal advice here. That wouldn't be possible because every attorney has a different set of demands and ways of presenting them so at best what I have posted is just an example of how to go about responding to admissions.