I know I'm getting ahead of myself here, but I don't want to leave anything out. If you had a chance to ask a collection agency anything you wanted to about their busines, procedures, etc....what would it be? I've already got the following: 1. State the name, address and job title or position with the Defendant of each and every person answering these interrogatories. 2. State the name and present address of each person known to the Defendant who has knowledge of facts bearing upon or relating to this lawsuit and summarize the facts known to each. This request is not limited to but necessarily includes, each and every person you may call as a witness at trial. 3. State the name, address and field or area of expertise of each expert witness expected to testify on behalf of the Defendant at the trial of this case, and set forth the qualifications of each. 4. State the name, address and phone number, of every person who has either disputed (either in whole or in part) an alleged debt or requested validation of an alleged debt with the Defendant within the last (5) five years and summarize the nature of the dispute in each case, along with the eventual outcome of each dispute. 5. For each legal proceeding to which the Defendant has been a party, whether civil, criminal, bankruptcy or other proceeding, please state the style and case number of the proceeding, the court in which the proceeding was or is pending, and describe the nature of the proceeding and the outcome of the proceeding. 6. Please state the name listed on Defendantâ??s current Articles of Incorporation, along with the state in which Defendant is incorporated, as well as any d/b/a or fictitious names used by the Defendant within the last ten (10) years and the date(s) such names were used, and list each of the officers of the corporation. I had a whole bunch I had thought of yesterday, but as usual when I don't write it down, I forget! Thanks! L
