Spent a long day doing some last minute shopping.....I'm such a procrastinator Anyways, I guess EXP was feeling in a jolly mood and decided to send their version of Scrooge greetings, about 50 Q's of interrogatories. What a bunch of losers, who the HECK sends interrogatories on CHRISTMAS EVE? WHO???
Thanks Butch, you are the best! I have 35 days to answer. It's 30 days per the request, and add an extra 5. Anything mailed gets an extra 5 days. The Q's are primarily a request for varying documents. They are getting the answeres in exactly 35 days from now. Not a day sooner. I just spoke with them last week, their counsel. We were in the middle of an offer, about the fourth one. This is just cheap, to let me believe we are in the middle of an offer, and SURPRISE. Oh well, I was going to formally rescind the last offer after the holidays. I just found out some pertinent information relating to the case/offer that is in my favor. It is looking like it is officially ON. So I say, bring it on EXP.
Not familiar w/your case to date, so this may be obvious - can you return the favor and ask them to produce lots documents?
Yes, I can. Late to mid next month I plan on submitting our own requests. Mostly, I am going to mirror their requests and add some of our own. For interog's., there were 60 different requests. They also ask about another 50 or so with a request of Admissions. There is another poster on CB suing EFX, and I was asked the same EXACT requests as her. Seems like the CRA's share discovery material. I recently spoke with counsel and told them we would not be available until mid next month. Also, I thought it was implied between the parties that discovery would not begin until either a rejection or accepance of the last offer made. I guess EXP took this as a cue and decided to bombard me when we would least expect it, the day before Christmas EVE. Too bad they can't take this principal of sharing discovery material and apply to erroneous tradelines.....LOL.
Re: Re: Merry Christmas *EXP STYLE Don't forget to send them on a wild paper chase. Since they are a Corporation, LLC or some other Artificial Person, you have the right to demand they produce the following documents just to show taht they are the legal entity they say they are: 1: Certified Copy of their Organizing Documents, and certified copies of any sunsequent amendments thereto 2: Notice of Good Standing from their home state Tax Departments stating that their filing fees and filing of informational documents are current - or else their entity status may have lapsed. 3: List of Current Officers and Directors 4: Name, business address, title and telephone number of deponent answering your Discovery Motion (for purposes of subpoena against that person to appear at trial to explain the documents)
Re: Re: Merry Christmas *EXP STYLE Hmmm.....thanks for the suggestions Flyingifr. I was planning on asking #3 and #4. Q's number 1 and 2 are something that hadn't crossed my mind.
Re: Re: Merry Christmas *EXP STYLE Maybe we should have a post for just their inquiries... so we could all be ready in advance That would surprise them a bit.
Re: Re: Merry Christmas *EXP STYLE That's a good idea. I'm lucky and grateful that another poster from CB has shared their interog's. Really helps give me a starting point on answering all the Q's, a lot of which are exactly the same as hers. At this point, I don't want to post the specific q's of EXP. I **think** they are bullies, and posting this stuff would be too confrontational and revealing. They are bullies, dh and I are better off letting them believe their strategy, which is based upon intimidation is effective. Nobody prepares for war against an ant.
