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Monica Graham
22365 Hayworth Court
Corona, CA 92883
951-316-3298
Monica_graham@rocketmail.com

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For the Alleged Defendant, In Pro Per

SUPERIOR COURT OF CALIFORNIA

COUNTY OF RIVERSIDE

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ASSET ACCEPTANCE LLC,

Plaintiff(s),
vs.
MONICA GRAHAM,
Defendant.

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Case No. RIC 1100709

ALLEGED DEFENDANTS
INTERROGATORIES TO PLAINTIFF
SET ONE

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Propounding party: Alleged Defendant - Monica Graham

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Set no. 1

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Responding party:

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To Plaintiff, ASSET ACCEPTANCE, LLC:

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Plaintiff ASSET ACCEPTANCE LLC

INSTRUCTIONS

YOU ARE REQUIRED, pursuant to California Civil Code section 2031.010 et seq by and through
an authorized officer of your company, and that the response be signed by the person making them
and be served on Plaintiff, Monica Mitchell, within 30 days of service of these interrogatories at:
22365 Hayworth Court, Corona, California 92883.
Alleged Defendant requests full compliance with the provisions of the California Code of
Civil Procedure 2031.210 et seq, including the requirement that the Responding Party identify why

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certain documents are not being produced (i.e., documents have never existed, documents are lost,

stolen, misplaced, etc.)

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For purpose of responding to these requests, the term identify shall mean providing the full name,
aliases, title, work address and work telephone numbers, work email address of the person or entity.
Plaintiff means employee, agents, attorneys, investigators, etc. of Plaintiff in this action.
For purposes of responding to these requests, the term document shall mean all written or printed
matter of any kind, including originals, and all non-identical copies or otherwise, including, without

limitation, correspondence, e-mail, memoranda, notes, diaries, statistics, letters, telegraphs, minutes,

addenda, expense accounts, contracts, reports, studies, checks, statements, receipts, returns,

summaries, pamphlets, books, inter-office and intra-office communications, notations of any sort of

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any conversations, including telephone conversations or meetings bulletins, computer print-outs,

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teletypes, telefaxes, invoices, worksheets, any alterations, modifications, changes, and amendments

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of any of the foregoing.

For purposes of responding to these requests, the term document also includes, but is not limited to,
all graphic or manual records, or representations of any kind (including, but not limited to,
photographs, charts, graphs, microfilms, microfiche, videotapes, records, and motion pictures), and

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all electronic, mechanical, or electric records or representation of any kind, including, but not limited

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to audio tapes, cassettes, discs and recordings.

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For purposes of responding to these requests, the term Contract is the document that established a

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contract between Plaintiff and Alleged Defendant. Each of these requests is addressed to the personal

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and continuing knowledge of plaintiff and plaintiffs counsel. If plaintiff cannot respond to any

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request due to lack of information available to it, alleged defendant requests that the plaintiff respond
to those portions of the request it is able to answer and specifically state that portion of the request it
cannot answer due to lack of information, and provide a reason why it believes it lacks sufficient
information to respond. If any of these requests cannot now be answered because of lack of
information or documentation and such information or documentation subsequently comes to the

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knowledge of plaintiff or plaintiffs counsel, alleged defendant requests plaintiff to serve

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supplemental documentation on alleged defendant within a reasonable time after such information or

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documentation is acquired.

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Interrogatory no. 1. Identify the person(s) who have answered these interrogatories.

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Interrogatory no. 2. Identify each and every person Plaintiff may call as a witness in this case, or
- 2 INTERROGATORIES SET ONE

other disposition of this matter, and provide a brief description of what you anticipate the witnesss

testimony to be.

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Interrogatory no. 3. Identify each and every document Plaintiff may introduce into evidence in this
case.
Interrogatory no. 4. Identify fully who the Lender is, as described in the Contract. If more than
one exists, state each.

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Interrogatory no. 5. State where in the Contract lender will change when the contract is sold.

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Interrogatory no. 6. Identify fully the individual who took the original Contract application.

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Interrogatory no. 7. Identify fully the person(s) who witnessed the Alleged Defendants signature
on the Contract.
Interrogatory no. 8. Identify fully the person(s) who have answered these questions.

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Interrogatory no. 9. State the date and amount(s) when the alleged amount in question was charged

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off.

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Alleged Defendant, Monica Graham, demands that the above-listed items be produced on or before

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April 19, 2011, at: 22365 Hayworth Court, Corona, CA 92883.

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Dated:______________________

By: ________________________________
Monica Graham
Alleged Defendant, Pro Per

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PROOF OF SERVICE BY MAIL (C.C.P. 1013a, 2015.5)

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STATE OF CALIFORNIA
COUNTY OF Riverside

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I ,_J. Davis__________, declare as follows:

I am employed in __Riverside______ County, I am over the age of eighteen
years and am not a party to the within entitled action; my business address is:
_1939 Natalie Ln., Riverside, CA 92506_________________

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On March 14, 2011, I served the following:

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ALLEGED DEFENDANTS INTERROGATORIES TO PLAINTIFF SET ONE

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On interested parties in said action by priority mail, postage prepaid, addressed as

follows:

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ANN K. MERRILL
FULTON FRIEDMAN & GULLACE, LLP
2151 SALVIO STREET
SUITE W
CONCORD, CA 94520
I personally deposited with the U.S. Postal Service on that same day with
postage thereon fully prepaid at _Corona___________, California, in the ordinary
course of business. I am not a registered California process server.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on

3/14/2011

, at

Corona

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________________________________

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, California