LAW OFEICES: HOW RD LEE SCHIFF, P.C 340 Main Street, Suite 959; Worcester, MA 01608-1603 ‘Tel. No. 508-753-9991; Fax No. 508-753-0260 Yebruary 17, 2005 Jean F_ O'Meara 153 Alvin Avenue Milton, MA 02186-5110 RE: Discover Bank vs. Jean F, O’Meara Civil Action Number 0456 CV 2030 Our CN K&7619 Dear Ms, O"Mcara: Enclosed please find a copy of the Plaintiff's First Set of Inturrogatories Propounded to the Belen rst Request for Production of Documents Propounded to the Defendant. Thank you for your attention and consideration. Sincerely, Lt, Tite Harry fheodoss, Esq. HITiwp Enclosures THIS COMMUNICATION IS FROM A DEAT COLLECTORCOMMONWEALTH OF MASSACHUSETTS NORFOLK, ss. DISTRICT COURT DEPARTMENT QUINCY DIVISION CIVIL ACTION NO. 0456 CV 2039 DISCOVER BANK, Plaintiff Vs. JEAN F. O"MEARA, Defendant I I | i | | | I PLAINTIFF'S FIRST SET OF INTERROGATORIES PROPOUNDED TO THE DEFENDANT ‘The Plaintiff, Discover Bank, by its attorneys, hereby serves its first set of interrogatories, to be answered under oath by the Defendant, in accordance with Massachusetts Rules of Civil Procedure 33. 1 Please state your name, 2. Did you enter into a credit card agreement with Discover Bank? 3. Please state with respect to the receipt of your Discover Bank eredit card: a. The approximate date you received your credit card. b, Whether you ever used said credit card ¢. Whether you received monthly account statements. 4. Did you in fact use said credit card to purchase goods: and services for the amount set forth in the Plaintiff's complaint? 5 If the preceding interrogatory is answered in the negative, did you authorize someone to use it on those dates and, if so, state: a. His/her fall name. b. Address. c. Relationship to you.10. M. 12. If you did not authorize someone to use your credit card for the amount set forth in the Plaintiff's complaint, state in detail the cizcumstances of such use and the name and address of the person who used it. State whether or not you owe the Plaintiff the amount set forth in the Plaintiff's complaint, exclusive of interest, If your answer to the preceding interrogatory is in the negative, please state: a, What amount, ifany, you admit owing the Plaintiff? b. Fully and in detail the facts upon which you rely in denying liability. If you deny owing the Plaintiff any money, please indicate: a Other than your answer, have you ever notified the Plaintiff of your dispute? b. _If'so, was it in writing or orally? c. The dates of these communications and with whom they were made. For each conversation between the Plaintiff or its agents, and Defendant, or her agents, representatives or anyone acting on her behalf, please state: a, who participated in the conversation or was present during the conversation without participating in it, the date of the conversation; how the coramunication took plac: ‘where the conversation took place; the substance of what each party to the conversation said; Whether any document exists that sets forth, summarizes, refers to or relates to the substance of the communication and, if so, identify such document. maags Identify each document or tangible thing thet you intend to present as an exbibit at the trial of this action. Identify all witnesses who may testify at tial and the substance of each witness” testirony