Initial Business Response / [redacted] (1000, 9, 2015/09/03) */ We are preparing to file a defamation and collection lawsuit against Ms [redacted] I will forward a copy to you after it's filedAfter the time for a responsive pleading passes, I anticipate sending your office a subpoena duces tecum for the production of recordsWhether I will need your testimony will depend in part on Ms [redacted] ' willingness to accept business records affidavit in leu of your testimoney In the meantime I ask that you keep careful records of those persons or organizations that you inform about this complaintTheir testimony as well as yours may be required Once the lawsuit is filed I will be at liberty to answer any questions you may have about the merits of the complaintThank you for your consideration [redacted]
Initial Business Response / [redacted] (1000, 9, 2015/09/03) */ We are preparing to file a defamation and collection lawsuit against Ms [redacted] I will forward a copy to you after it's filedAfter the time for a responsive pleading passes, I anticipate sending your office a subpoena duces tecum for the production of recordsWhether I will need your testimony will depend in part on Ms [redacted] ' willingness to accept business records affidavit in leu of your testimoney In the meantime I ask that you keep careful records of those persons or organizations that you inform about this complaintTheir testimony as well as yours may be required Once the lawsuit is filed I will be at liberty to answer any questions you may have about the merits of the complaintThank you for your consideration [redacted]