Complaint Review: Palisades Collection Inc. - Englewood New Jersey

are pretty smart guys. I have an interrogative of my own, you'll love it: I think the main thing to remember is, NO COLLECTIONS AGENCY has proof of anything. Pursuant to Article 3120 of the Civil Practice Law and Rules, your name, SS#999-99-9999, defendant herein, demands that Aargon COLLECTIONS, having possession of information material and necessary in the prosecution or defense of the above captioned matter or their attorneys produce and furnish to the undersigned to the defendant your name, at your address on or before (30 days)Month day, 2009 all documents and things set forth: INSTRUCTIONS: As used under this Request: 1. The term document is intended to be comprehensive and to include, without limitation, all original writings of any nature whatsoever, copies, and drafts which, be reason of notes, changes, initials or identifications marks are not identical to the original, and all non-identical original copies thereof. In all cases where original and/or non-original copies are not available, document also means identical copies of original documents and copies of non-identical copies. 2. The term document includes, but is not limited to, correspondence, memoranda, agreements, records, reports, evaluations, summaries, opinions, journals, notes, transcriptions, telegrams, teletypes, telex messages, telefaxes, recordings of telephone calls, emails printouts and all other communications, including but not limited to notations, notes, memoranda and other writings of or relating to telephone conversations, tapes or other recordings, logs and any other information which is stored electronically, by means of computer equipment or otherwise, and which can be retrieved and printed, graphic, or audio form. 3. The term relating to includes referring to, embodying, in connection with, commenting on, corresponding to, sharing, describing, concerning, analyzing, reflecting or constituting. 4. Terms in the plural include the singular and terms in the singular include the plural. 5. A request that the party produce documents means that the party must produce all documents in possession of the party, and all documents belonging to the party in the possession of the parties representatives, agents, employees, or attorneys. 6. If any document described in this request was, but no longer is in your possession or subject to your custody or control, or in existence, please state whether it is missing or lost; whether it has been destroyed; whether is has been transferred, voluntarily or involuntarily, to others; or whether is has been disposed of otherwise. In each instance explain the circumstances surrounding such disposition and identify the person directing or authorizing the same, and the date thereof. Identify each such document by listing its author, and the author's address, type of document (e.g., letter, memorandum, telegraph, or email), date, subject matter, present location and custodian, and state whether the document (or copies) are still in existence. 7. If any document, or any portion of any document, is withheld under claim of attorney-client privilege or upon any other ground, the petitioner withholding the document shall furnish a list, signed by the person supervising the response to this request, identifying each document withheld and stating with respect to each: a. the date and number of pages of the document and the identities of author, addressee, and each person to whom copies were send or were to be sent; b. the subject matter of the document; c. the identity of each person to whom the document, its contents, or any portion thereof is known or has been disclosed; d. if the document is withheld on the grounds of attorney-client privilege; (i) each basis for such claim of privilege and (ii) the identity of each person who was privy to any assertedly privileged communication reflected in the document; and e. if the document is withheld on any ground other than attorney-client privilege, each basis which respondent contends justifies withholding the document. 8. The term the media includes, without limitation, television, newspapers, magazines, radio, and internet websites. Time Frame 1. All requests for documents cover the period from January 2003 to Present, unless otherwise specified. Pursuant to CPLR 3101, Petitioner is required to supplement or amend its response promptly after securing information which would make the previous response materially misleading. DOCUMENTS REQUESTED 1. All documents including but not limited to original documents, drafts of original documents, photocopies relating to the original contract entered into between Dominion Gas and defendant. 2. All documents, including but not limited to original documents, drafts of original documents, photocopies related to original contract entered into between Dominion Gas and defendant for account in question. 3. All documents including but not limited to original documents, drafts of original documents, photocopies, monthly billing statements listing all alleged charges, receipts of payment, cancelled checks, and all other documents regarding the billing of defendants account in question. 4. All documents including but not limited to audio recordings of telephone conversations between Dominion Gas and defendant relating to account in question. 5. All documents including but not limited to transcripts of recordings of telephone conversations between Dominion Gas and defendant relating to account in question. 6. All documents including but not limited to audio recordings of telephone conversations between Dominion Gas and defendant. 7. All documents including but not limited to transcripts of recordings of telephone conversations between Dominion Gas and defendant. 8. All documents including but not limited to original documents, drafts of original documents, photocopies, correspondences, e-mails, telephone log entries, demand for payment notices and all other documents sent by Dominion Gas to the defendant. 9. All documents including but not limited to original documents, drafts of original documents, photocopies, correspondences, e-mails, telephone log entries, demand for payment notices and all other documents sent by AARGON Collections to the defendant. 10. All documents including but not limited to records of telephone calls, records of telephone logs, audio tapes made of telephone calls, and messages left, and transcripts of telephone calls made by Dominion Gas to the defendant. 11. All documents including but not limited to records of telephone calls, records of telephone logs, audio tapes made of telephone calls, and messages left, and transcripts of telephone calls made by AARGON Collections to the defendant. 12. All documents that reflect that due demand for payment has been made by Dominion Gas to defendant. 13. All documents that reflect that due demand for payment has been made by AARGON Collections to defendant. 14. All documents including but not limited to original documents, drafts of original documents, correspondences, notes, emails, and all other documents relating to the alleged cancellation of defendants Dominion Gas services. 15. All documents including but not limited to audio recordings of telephone conversations between defendant and AARGON collections. 16. All documents including but not limited to original transcripts, copies of transcripts, and all other documents relating to telephone conversations between the defendant and AARGON collections. 17. All documents including but not limited to ledger sheets, balance sheets, financial documents and all other documents relating to the calculation by Dominion Gas of the alleged amount of debt owed by defendant. 18. All documents including but not limited to ledger sheets, balance sheets, financial documents and all other documents relating to the calculation by AARGON collections of the alleged amount of debt owed by defendant. 19. All documents including but not limited to original documents, drafts of original documents, photocopies relating to the original contract entered into between Dominion Gas and AARGON collections. 20. All documents including but not limited to original documents, drafts of original documents, photocopies relating to the written notice pursuant to and required by Section 809 of the FDCPA (15 USC 1692g) send from AARGON collections to the defendant. 21. All documents including but not limited to original documents, drafts of original documents, photocopies relating to the written notice pursuant to and required by Section 809 of the FDCPA (15 USC 1692g) send from Dominion Gas to the defendant. THE FOREGOING DEMAND IS A CONTINUING DEMAND. IN THE EVENT ANY OF THE ABOVE ITEMS ARE OBTAINED AFTER THIS DEMAND, THEY ARE TO BE FURNISHED TO DEFENDANT, your name AT your address, WITHIN (30) DAYS OF RECEIPT BY DEPONENT OR HER ATTORNEY. IF NONE OF THE ABOVE ITEMS EXIST, YOU ARE TO SO STATE IN A SWORN REPLY TO THIS DEMAND. PLEASE TAKE FURTHER NOTICE, that upon your failure to produce the aforesaid information and/or documents, a motion may be made to preclude your upon the trial of this motion from offering evidence relating thereto, whether such evidence consists of written records or oral testimony. If none of the above items exist, you are to so state in a sworn reply to this demand. Additionally: Defendant your name, is NEVER to be contacted via phone or email. This is your NOTIFICATION. Only means of communication are via POSTMAIL ONLY. Dated: Pittsburgh, Pennsylvania February 24, 2009 Yours,

Here is the update as promised. Those idiots at Palisades Collections thought just because they sued me almost six (6) years after Verizon sent me a telephone bill I wouldn't have a copy of them and that they could file a phony Verizon bill with the court. Guess what? I still had the original Verizon bills and I still have the original receipts proving I made payments on the bills six years ago. So, I prepared opposition papers to Palisades motion for summary judgment and I informed the judge of their fraudulent conduct. I also informed the judge that Palisades assignment was invalid because the signature on it is illegible and it failed to identify what bills were assigned to Palisades. The assignment mentioned an agreement with Verizon; but no agreement was attached to Palisades summary motion that may have identified the assigned bills. This was in addition to the statute of limitation passing. I will be moving to dismiss their complaint and I will be filing a federal lawsuit against them for fraud among other causes of action. These people are crooks and a bunch of idiots. They are a bunch of amateurs. I'm sure they were real surprised when I pulled out the original six year old Verizon bills and the original payment receipts. They didn't see that one coming. I mean who holds on to telephone bills for six years? I did. Don't let these idiots cheat you. Go after them.