Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00636-JBA

Document 31-2

Filed 03/05/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EVELINE GOINS v. JBC & ASSOCIATES, P.C. ET AL. CASE NO. 3:03CV 636 (JBA)

January 29, 2004

SECOND DISCOVERY REQUEST The plaintiff requests each defendant to respond to the following interrogatories under oath. Please see Local Rule 26 for definitions. " Documents" includes electronic transmission, and writings and recordings as defined in Fed. R. Evid. 1001. These interrogatories shall be deemed continuing so as to require supplementary answers if you obtain further information between the time answers are served and the time of trial. INTERROGATORIES 12. Describe all procedures reasonably adapted to avoid communicating with a debtor known to be represented by counsel. 13. Describe all procedures reasonably adapted to avoid sending letters into states in which you are not licensed to do collections. 14. Describe all procedures reasonably adapted to avoid miscalculation of the amount due on a dishonored check. 15. Describe the meaning and use of Code DMP. 16. Describe the meaning and use of Code UNRTRN. 17. For each alleged dishonored check you are collecting as plaintiff' please set s, forth the date of the check, the amount of the check, the date you received the check for collection, and the date of each collection letter sent.

Case 3:03-cv-00636-JBA

Document 31-2

Filed 03/05/2004

Page 2 of 2

18. Identify the printing concern you use for letters to Connecticut debtors. 19. Identify the company which provides the CRS software you use for collection. 20. Identify all Closing Codes (e.g., 42, 49) and set forth which ones permanently close an account, and how each one affects the ability to reopen an account. 21. Please state when defense counsel learned that plaintiff had filed bankruptcy. 22. Please state when defendants learned that plaintiff had filed bankruptcy. PRODUCTION 15. Manuals describing the fields and codes for entries on the CRS software. 16. A copy of all dishonored checks you claim were issued by Ms. Goins. 17. A copy of all notices sent by each payee of such dishonored checks to Ms. Goins. 18. A copy of the employment or retainer agreement of each " counsel" of . 19. All documents concerning each of plaintiff's alleged dishonored checks and defendant's efforts to investigate and collect thereon, including internal collection records, audit records, and correspondence. 20. All Fact Sheets concerning each of plaintiff'alleged dishonored checks. s

THE PLAINTIFF

BY______________________ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 06511-2422 (203) 772-0395

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