First off, I want to say hello to everyone on this forum. I've been lurking for the past couple of months in order to get some info on how to deal with a bottom feeder CA. Five months ago, my ex-wife received a summons for a lawsuit in regard to an old Capital One card she had. She asked for my help and after looking over info here, we went to the court house and registered her intent to defend a week later. The last transaction that took place on this card was Nov, 2002, so it's well outside the SOL for Georgia and that was going to be the defense. I probably should have pressed on with that but didn't at the time because it appeared that the CA was basically going to drop it. Well this week she received another large piece of mail from the CA with the following items in it: Request for Admission of Facts Request for Production of Documents and Notice to Produce to Defendant Plaintiff's First Interrogatories to Defendant All 3 have the usual paragraphs that have been talked about in other threads. I didn't want to crowd this posting too much with them, but if anyone needs them listed I'll be glad to do that in another posting. What I was interested in finding out was if the best course of action in this would be to just basically answer each request and all the paragraphs in them with the simple statement: Paragraph #: Denied cause the alleged debt is time-barred by the Statue of Limitations for the state of Georgia. Then at the end of each document, I would include the necessary info as to TILA and the fact that credit card are considered open accounts and not written contracts and so on Again, I'm trying not to overburden you with too much info, but anything else you may need, I'll be happy to put in another post. Thanks for all the help already received from reading other posts in the forum and for the future help.