Interrogatories to Plaintiff Junk Debt Buyer

Interrogatories are written questions asked of the opposing party.  The answers should be “verified”.  Interrogatories are questions asked under oath and a verification should accompany the responses.  This is basically a signed document that is returned to you along with the written answer.  This signed document should be that of the Plaintiff, for example, an employee or custodian of records if a debt buyer, and the signature should be notarized.  Often times, the debt collection law firm doesn’t bother to send any verification with their responses, because they’ve either objected to every single request you’ve made or they doubt you’ll notice they didn’t send one anyway.

There are no limits imposed on the number of Requests for Production of Documents or Request for Admissions you may serve.  However, there are restrictions placed on the number of Interrogatories you may serve according to O.C.G.A. § 9-11-33. The limit is 50 and that includes sub-parts of questions.


If you don’t understand the discovery requests you are sending, don’t send them.  It won’t do you any good.  Remember, there’s no discovery in Magistrate court so it won’t do you any good to send these if that’s where you’re being sued.  You’re going to look like a dumbass.

The following are the more popular Interrogatories I’ve seen sent to plaintiff junk debt buyers:

State the name(s), business address(es) and job title(s) or capacity(ies) of the officer(s), employee(s) or agent(s) answering or providing any information used to answer each Interrogatory.

State the legal name of your organization.

State any other names which your organization uses to identify itself, whether such names are registered with any official, and the date and place of such registration.

State the form of your organization, the date and place the organization was organized and registered and/or licensed to do business.

Is <junk debt buyer name here> the direct assignee of <original creditor name here>?  Or, is <junk debt buyer name here> an assignee of an assignee?  If there are additional assignees, identify each assignee, their business address, and telephone number.

Identify any person who has knowledge of facts relating to this lawsuit, and specify his or her area of knowledge.

Identify all witnesses Plaintiff proposes to call to trial.

Identify the person(s) responsible for the books and records of the defendant including name, including title, years with the company, as well as years of experience in their field.

List all exhibits Plaintiff proposes to introduce at trial.

Do you have an actual contract between the Defendant and <original creditor name here>?

Do you have the assignment agreement between <original creditor name here> and <junk debt buyer name here>?

In regards to the contract or agreement alleged in this action, please state the following:

a.  Terms of the Contract or Agreement;
b.  Credit Limit Amount Financed in the Alleged Contract or Agreement;
c.  Date and Monetary value of any valuable consideration received on the contract or agreement;
d.  Date and Monetary value of any payments or credits alleged to be executed on the contract or agreement.

State all actions taken to verify the accuracy and completeness of the account which is the subject of this lawsuit.

State your procedures designed to assure the maximum possible accuracy of a debt if disputed by a consumer.

How did you locate Defendant?

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