# Requests for Production — Debt-Buyer Case A ready-to-adapt RFP set for a pro se defendant in a debt-buyer case. Edit the bracketed terms, number of requests, and definitions to fit your case. ## Format ``` [COURT HEADER AND CAPTION] [DEFENDANT'S] FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO [PLAINTIFF DEBT BUYER] TO: [Plaintiff's counsel of record] AND TO: [Plaintiff] Pursuant to CR 34 / CRLJ 34, [Defendant] requests that [Plaintiff] produce the following documents for inspection and copying within 30 days of service, at [Defendant's address] or another mutually agreed location. DEFINITIONS 1. "Account" means the credit account identified in Plaintiff's Complaint as account number [####], issued by [original creditor] to Defendant. 2. "Original Creditor" means [original creditor as named in the Complaint]. 3. "You" or "Your" means Plaintiff, its agents, employees, assignees, and counsel. 4. "Document" has its broadest meaning under CR 34(a), including electronically stored information, emails, account notes, system records, and reproductions. 5. "Assignment" means any transfer of ownership, in whole or in part, of the Account. 6. "Charge-Off" means the event by which the Account was written off as uncollectable by Original Creditor. INSTRUCTIONS 1. Produce all documents in Your possession, custody, or control, including those held by agents or predecessors. 2. If any document is withheld on a claim of privilege, produce a privilege log identifying the document, author, recipients, date, subject, and basis for the privilege. 3. Continuing obligation: supplement responses promptly if new responsive documents come into Your possession (CR 26(e)). REQUESTS REQUEST NO. 1: All documents evidencing the agreement between Original Creditor and Defendant, including without limitation the signed application, cardholder agreement, terms and conditions, and any amendments. REQUEST NO. 2: All monthly account statements for the Account from origination to the date of Charge-Off. REQUEST NO. 3: The statement issued immediately after Charge-Off reflecting the final balance, principal, interest, and fees as of Charge-Off. REQUEST NO. 4: All documents evidencing the assignment, bill of sale, or other transfer of the Account from Original Creditor to the first purchaser, including all schedules, exhibits, or attachments identifying the Account within the transferred portfolio. REQUEST NO. 5: All documents evidencing each subsequent assignment or transfer of the Account, from the first purchaser to You, including schedules, exhibits, and attachments identifying the Account by account number or name. REQUEST NO. 6: All documents reflecting the price paid by You for the Account, including the portfolio price, any allocation or weighting, and documents showing the portion of the purchase price allocated to the Account. REQUEST NO. 7: All communications between You and Original Creditor, or between You and any intermediate purchaser, concerning the accuracy, completeness, or warranties of the records of the Account. REQUEST NO. 8: All purchase agreements, master forward flow agreements, or similar contracts under which the Account was transferred, including any provisions limiting warranties or disclaiming accuracy. REQUEST NO. 9: All records of payments made by Defendant on the Account, with dates, amounts, and posting methods. REQUEST NO. 10: All documents showing calculation of the balance claimed in the Complaint, including principal, interest rate(s), interest calculations, fees, and any credits or adjustments. REQUEST NO. 11: All account notes, call logs, collector notes, or comment histories for the Account, whether maintained by You or by Original Creditor or any intermediate purchaser. REQUEST NO. 12: All documents showing the date of the last payment made by Defendant on the Account. REQUEST NO. 13: All dispute correspondence, validation requests, and responses regarding the Account — whether sent by or received from Defendant. REQUEST NO. 14: All documents showing Your license to conduct a collection-agency business in Washington under RCW 19.16.110. REQUEST NO. 15: All documents identifying the custodian(s) of records for each set of documents produced, including the person with personal knowledge of the recordkeeping practices of Original Creditor. REQUEST NO. 16: All credit-bureau reports or tradeline furnishings You have made regarding the Account. REQUEST NO. 17: All collection letters, notices, or written communications sent to Defendant regarding the Account from January 1, [year], to present. REQUEST NO. 18: All telephone recordings, voicemail records, and logs of telephone calls between You or Your agents and Defendant. REQUEST NO. 19: All training materials, compliance policies, and operating procedures addressing FDCPA compliance and accuracy of collection records. REQUEST NO. 20: All documents You intend to use or introduce as evidence at any hearing or trial in this matter. DATED this ___ day of __________, 20__. ____________________________________ [Defendant Name], pro se [Address] [Email] ``` ## Notes on request design - **Request 1–5** establish standing and chain of title (the usual point of failure) - **Request 6–8** reveal the disclaimer-of-accuracy language in forward-flow agreements — often a CPA / FDCPA predicate - **Request 9–13** establish the account history and any restart events for SOL purposes - **Request 14** tests licensing compliance under RCW 19.16.110 - **Request 15** pre-empts the "remote custodian" foundation - **Request 17–19** supports the FDCPA / CPA counterclaim - **Request 20** forces identification of all trial exhibits — failure to produce forecloses later use ## Common plaintiff objections and how to handle - "Proprietary / trade secret" → request protective order (CR 26(c)) - "Overly burdensome" → narrow the time range or category; if still refused, meet and confer, then motion to compel - "Not in possession" → pin with RFA to admit non-possession - "Unduly cumulative" → respond that these are distinct documents (agreement ≠ monthly statement ≠ bill of sale) ## Common pitfalls - Asking for "all documents related to the Account" — too vague, will be objected to. Use specific categories - Requesting the original creditor's documents without specifying — plaintiff may disclaim possession. Pair with RFA - Failing to define "Account" precisely — plaintiff may produce a different account's records