STATE OF WYOMING	)	IN THE DISTRICT COURT
					) ss.
COUNTY OF ________________	)	_______________ JUDICIAL DISTRICT

_______________________ 			)	Civil Action Case No. __________ 
PLAINTIFF					)
						)
VS.						)
						)
_________________________________	)
DEFENDANT					)	

DEFENDANT’S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF

	Now Comes . . .

INTERROGATORIES

1.	Please identify all persons providing information used in responding to these interrogatories by setting forth their name, position of employment, years in that position, years with the company, date of birth, social security number, and a list of all crimes to which they have been found guilty or entered a plea of guilty, with the exception of municipal court convictions.

2.	Please identify all individuals who will be called to provide expert testimony by setting forth their name, topic on which expert testimony will be provided, their qualifications to provide such opinion testimony and a list of all cases in which they have previously testified, to include the case name, court and case number.

3.	Please list by date every account balance, interest charged, fee charged, payment receipt, and all other credits or debits leading to the alleged account balance.

4.	For each item listed in the previous interrogatory, please identify what provision in the agreement between the parties authorizes the charge or the law being relied on to add sums due to the account.

5.	Please list all payments received and the date received on and how those payments were distributed amongst the outstanding principal, interest, and each separate category of fee, penalty or other charge added to the account maintained by the Plaintiff or its assignors.  

6.	If the Plaintiff is an assignee, please describe all assurances, reviews, processes, and any other steps taken to support the Plaintiff’s claim that the alleged debt is owed.

7.	List each item allegedly purchased by Defendant, the price charged for each item and from whom purchased.  

8.	For each charge or purchase, please state:
		(a)	Whose signature was on the credit slip;
		(b)	What item was purchased or good received;
		(c)	The amount charged for each such item or service.

9.	List each and every person who was authorized to use the credit card.

10.	State who generated each record or document Plaintiff intends to rely on at trial.

11.	What is the name, title, address, and phone number of the person in charge of Plaintiffs records?

12.	Who, other than above, at Plaintiff’s company can testify as to the Agreement made with Defendant and the rates and fees actually assessed to Defendant. For each, please provide name, title, address, and phone number.

13.	Was the Defendant ever charged an interest rate, finance charge, late, over the limit, or any other fee not described to and agreed to by Defendant?

14.	How was interest compounded on Defendant’s account?

15.	Were both the Annual Percentage Rate and effective Annual Percentage Rate disclosed to the Defendant?

16.	Did a point in time come when the Defendant’s original Account Agreement terms and condition change? If so, how was that change communicated and how is Plaintiff assured that the communication was effective?

17.	Was the Defendant advised of his/her ability to opt out of the change of terms and condition? If so, how was Plaintiff assured that this communication was effective? And how was Plaintiff assured of Defendant’s response in the affirmative or negative?

REQUEST FOR PRODUCTION OF DOCUMENTS

“Document” means any written, recorded or graphic matter, whether produced, reproduced or stored on papers, cards, tapes, belts, or computer devices or any other medium in your possession, custody or control, or known by you to exist, and includes originals, all copies of originals, and all prior drafts. It includes all original business records, non-identical copies, computations, memoranda of oral or telephone conversations, tabulations, records of correspondence, notes made on other documents, microfilms, etc. A request to identify a document is a request to state as applicable:

1. The date of the document;

2. The type of document;

3. The names and present addresses of the person or persons who prepared the document and of the signers and addressers of the document;

4. The name of the employer or principal whom the signers, addressers and preparers were representing;

5. The present location of the document;

6. The name and current business and home addresses of the present custodians of the original document, and any copies of it;

7. A summary of the contents of the document; and

8. If the original document was destroyed, the date and reason for or
circumstances by which it was destroyed.

1.	The alleged credit application from “Account”, bearing the defendant’s signature. 

2.	The alleged credit agreement from “Account” that states interest rate, grace period, terms of repayment, et cetera;

3.	The signed copies for all charge slips supporting said charges.

4.	Any statements or writing signed by Defendant that authorized attorney fees and/or interest.  

5.	All statements detailing penalties, fees or other sums added to the alleged account balance.

6.	Copies of all assignments of this account, if any, including amounts paid for said assignment.  

7.	Copies of all documents relied on by whomever signed the affidavit attached to your Petition.  

8.	Please produce all documents in support of the Affidavit attached to the Petition setting forth the account number and amount due thereon.	

9.	Please produce all signed copies and any contracts or agreements executed by the Defendant relating to the alleged account.

10.	If the Plaintiff is an assignee, please produce a copy of the assignment of this debt or account.

11.	Copies of any documents which purport to bear Defendant’s signature.  

DATED this ______ day of _____________________, 20____.

Signature

CERTIFICATE OF SERVICE
	
The undersigned hereby certifies that the foregoing instrument was served on the ___________ day of ________________, 20 ____ by depositing a true and correct copy of the same in the United States Mail, postage prepaid, and addressed to the following:
____________________________________    
____________________________________
____________________________________

______________________________
    Signature