In the court of county, alabama debt buyer, llc
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IN THE ________ COURT OF ________ COUNTY, ALABAMA
DEFENDANT’S SECOND SET OF REQUESTS FOR PRODUCTION Defendant requests that plaintiff produce the following documents within thirty days: All documents reviewed regarding or relating to the account of defendant by plaintiff’s vice-president Rhonda Horton before she executed the affidavit dated March 11, 2013 which has been produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All documents evidencing or supporting the facts stated in paragraph 3 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All documents evidencing or supporting the facts stated in paragraph 4 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All documents evidencing or supporting the facts stated in paragraph 5 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All statements sent to defendant as described in paragraph 6 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All documents describing or reflecting the mailing procedures of plaintiff or its attorneys as described in paragraph 7 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All documents evidencing or supporting the facts stated in paragraph 7 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. All “regular books of account” and “entries in said books of account” relating to defendant as referred to in paragraph 8 of Rhonda Horton’s affidavit dated March 11, 2013 produced by plaintiff. Please identify in your response the particular documents which are responsive to this request. A complete copy (including all exhibits) of the document to which the Bill of Sale from General Electric Capital Corporation and GE Capital Retail Bank dated January 9, 2012 was attached as Exhibit A. A complete copy (including all exhibits) of the Forward Flow Receivables Purchase Agreement dated as of January 7, 2011 by and between General Electric Capital Corporation, GE Capital Retail Bank (f/k/a GE Money Bank), and Atlantic Credit and Finance Special Finance Unit III, LLC. A complete copy (including all exhibits) of the March 16, 2012 Purchase and Sale Agreement between Atlantic Credit & Finance Special Finance Unit, LLC and Security Credit Services, LLC referred to in the affidavit of Christopher W. Hanson dated April 2, 2012 produced by plaintiff. A complete copy (including all exhibits) of the March 16, 2012 Bill of Sale between Atlantic Credit & Finance Special Finance Unit, LLC and Security Credit Services, LLC referred to in the affidavit of Christopher W. Hanson dated April 2, 2012 produced by plaintiff. A complete copy (including all exhibits) of the Receivables Purchase Agreement dated as of June 20, 2011 between Atlantic Credit & Finance Special Finance Unit, LLC and Security Credit Services, LLC referred to in the Bill of Sale dated March 16, 2012 produced by plaintiff. Attorney for Defendant Directory: wp-content -> uploads -> 2014 2014 -> For want of a nail 2014 -> Stop Militarizing Law Enforcement Act of 2014 2014 -> Ihbb asian Championships 2014 middle school bowl Round 4 First Quarter 2014 -> Ihbb european Championships 2014 Bowl Round 4 First Quarter 2014 -> International History Bee and Bowl 2013-14 Asian Division Question Set Bowl Round Six 2014 -> United states patent and trademark office 2014 -> Coffs harbour eisteddfod vocal syllabus 2014 -> Listen News Programs Schedule pledge now 2014 -> Slow club announce third album complete surrender Download 8.99 Kb. Share with your friends:
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