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I have been served a complaint against me for a credit card debt by a third party debt buyer. They are within the SOL.  I live in colorado and a court date has already been set. I have done alot of research and have already filled out my answer, affirmative defenses.  But, I'm having a problem figuring out if I should also file with my answer a "production of documents" or Admissions & request for production.  Which one if any do I send? Also, I read something about form 9 going with the production request..what is that? & do I need to send that too? Also, trying to figure out in colorado how many requests I can put in my request for production..if a limit or not? I have done my research but stuck on this, please help.. Thanks


Answer
Find your Colorado rules of Civil Procedure and you will get the answers to most of your questions. But "affirmative defenses"? Why on earth would you want to send anything like that? Don't know a thing about form 9. Never heard of it in Colorado law. I always use 30 demands for admissions and send those along with the response. Of course you don't file those with the court. You only send them to the plaintiff's lawyer. How about your demand for validation? Are you still within the 30 day limit on that? Or have you sent that to the lawyer already? Better send that too if you can.  

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Creditwrench

Expertise

Debt Collections law, Fair Debt Collection Practices Act (FDCPA), Fair Credit Reporting Act (FCRA), federal law, how to properly answer court summons for collection cases, how to prepare federal cases against debt collectors, how to deal with debt collection phone calls.

Experience

I've been an active consumer advocate for more than 40 years and have helped hundreds of people win cases against debt collectors as well as helping them defeat demands for summary judgment lodged against them by banks, debt collectors and defeat mortgage foreclosures and keep their homes.

Education/Credentials
Paralegal courses for the most part.
I have been teaching people how to deal with judgments, mortgage foreclosures and other such problems both on and off the internet for many, many years. I am a Richard Cornforth information provider ever since 2000 and worked with many other organizations and causes since 1980. I was Oklahoma State Chairman for the nationwide drive to defeat the Constitutional Convention which was proposed by various factions within our federal government such as the Council of State Governments and the National Organization of State Governors who were working hard to organize a Constitutional Convention to be held in 1995 for the purpose of rewriting our American Constitution to be more acceptable to the United Nations. I worked with Senator Charles Duke of Colorado and Senator Don Rogers of California and many others across the nation to keep them from getting the number of delegate states required to lawfully hold a Con-Con and we were successful. I have worked with many other legislative issues in Oklahoma and have always been very successful.

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