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New Century Financial Services, Inc.,		| Superior Court of New Jersey
Plaintiff						| Special Civil Part - Law Division
							| YOUR County
V							|
							| Docket No.: DC-XXXXX
Your Name,						|
Defendant						|
							| Defendants first set of discovery including 								| interrogatories,  requests for admissions 								| and request for the production

TO:	New Century Financial Services, Inc., 

Find below Defendant's first set of discovery to plaintiff that are made in good faith and reasonably calculated to lead to admissible evidence should this case proceed to trial. Thank you.

Sincerely,

Your Signature

Your Name Signed
DATE

1.  Provide the full name, business and home addresses and occupation of the person answering these interrogatories. 

Answer:

2.  Please provide the names, home and business addresses of each member of the Plaintiffs Board of Directors 

Answer:

3. Please provide the names, home and business addresses of each officer of the Plaintiff.

Answer:

4.  State the total amount of damages suffered by Plaintiff and indicate with specificity each action(s) of Defendant which caused said damage, the date of each alleged action, the damages suffered by Plaintiff, the date Plaintiff suffered said damages and the state the mathematical calculation of damages claimed by Plaintiff.

Answer:

5.  Identify and produce each document plaintiff will rely on at time of trial. 

Answer:

6. Provide the full name, business and home address and occupation of every witness plaintiff will call on to testify at the time of trial and provide a summary of the testimony, referencing any documents said witness will rely on. For each expert, specify separately, in addition to the above, the expert’s area of expertise, the expert’s employer, if any, the expert’s subject matter for testimony, the expert’s opinions and conclusions and the grounds upon which same are based.

Answer:

7. Please state the full name and address of each person having knowledge of the within cause of action, the knowledge possessed by each said person and the method by which said person acquired said knowledge. 

Answer:

8. Absent any admission from defendant, state how plaintiff will prove the defendants alleged debt.

Answer:

9. State the full amount in dollars plaintiff paid for defendants alleged debt and how Plaintiff validated the accuracy of the amount. Produce the sales contract, sales receipt and canceled check and if the sales receipt refers to any other document, please produce that document.

Answer:

10. If the disputed account has been charged off, disclose the date of the charge off and the individual or officer's name and address responsible for that accounting or record keeping function.

Answer:

11. Do you admit that as a matter of custom, policy and practice, you obtain judgment by default in the absence of your possession of the signed contract made by the defendant?
YES____  NO ____

12.  State with specificity the terms of all agreements you entered into with Defendant, including loan agreements, and for each provide:
(a) The names and legal addresses of all persons present at the signing of any such agreement;
(b) The names and locations of all persons possessing the loan documents;
(c) The origination of the disputed account;
(d) The names and locations of all institutions from which funds were drawn in originating the loan, or extending credit.

Answer:

13. Is the Plaintiff in possession of the original loan or credit "application" allegedly signed by the Defendant?
YES____ NO____

State of New Jersey  		 ) SS
County of                  		 )

Before me, the undersigned authority, duly licensed to administer oaths and take acknowledgments, personally appeared

______________________________________________________________________ who being first duly sworn, deposes and says that he / she has read the answers to the foregoing, and that they are true and correct to the best of his / her knowledge. 

Print Name: _______________________________________

Signature: _________________________________________(SEAL)

SWORN AND SUBSCRIBED before me this _____ day of ____________2003.

Notary Signature      _____________________________________(SEAL)
 
Print Notary Name:  ____________________________
			Notary Public of New Jersey

My commission expires ___________________