The other situations are more complicated than if the collector does not respond at all. If the debt collector requests additional time, the court will almost certainly grant it. His main goal in that situation is to force the debt collector to admit that he does not have any of the records in his possession. To push for this admission, you can oppose the time extension motion and ask for “partial” answers. Or you can wait, get answers from him, and then file a second set of interrogatories in which he requests the whereabouts of all information used to answer the first interrogatories at the time of the extension request.

Try to get them to admit they don’t have the materials you’re looking for

I find it important to obtain admission that the information was not in the possession of the debt collector at the time sought because the legal ethics of many states require that a case be independently reviewed by an attorney prior to filing to ensure there is merit to it. If they don’t have any of the records, how can they have done an “independent” analysis? Obviously they can’t have. Check your state’s legal ethics requirements, and if they admit they don’t have the documents, you might consider adding a Fair Debt Collection Practices Act (FDCPA) counterclaim on that basis. Because if they are violating state law or ethics by filing their claim against you, it is an “unfair” debt collection practice.

The answer to all objections

The most sophisticated and challenging situation is the answer to all objections. Of course, they will have objections to each of the things you seek. And since the attorneys have computerized forms filled with carefully worded objections, it will be a job for you.

This is a good time to get the job done

Still, this is a good time to put in long hours. A good result here is likely to result in a spectacular victory. Remember, the other side’s attorneys have a lot of forms ready to go, but they’re not used to people defending themselves. They’re not set up to handle aggressive actions, and if you’re tough at this stage, they’ll likely, as a client of mine put it, “fold like a cheap suit.”

Don’t let his appearance of calm and contempt fool you. You are a huge pain to them right now, and you are costing someone a lot of money. Or seen from a different point of view, you’re stopping them from suing another poor bum (probably dozens, actually) and putting them in the poor house.

You are doing a public service!

But however you want to look at it, you have an advantage, and the way to make it worthwhile is to push the knife and turn it. As fast as possible.