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Old 11-18-2013, 01:30 PM
ByMyself ByMyself is offline
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In your response, using Form 22A, you will address every "fact" line by line, and every piece of evidence, line by line. I assume you have the form in front of you.

The line numbers you do admit, enter in the appropriate spots where it asks you.

The ones you do not - explain why not, as the form provides a section for this purpose exactly.

Are any of the emails not addressed to you directly, but instead are third party? State you cannot authenticate due to that reason.

The emails that are partially blacked out - does it explain on their request to admit why they are blacked out? If it is because of legal privilege, they are entitled to black it out, but that should be explained in their Request. You can refuse to authenticate because you cannot read the entire content of the email.

Just be careful that you aren't objecting just for the sake of it, and it is regarding something relevant.

The emails that have been written on - maybe try saying you will not authenticate because document has improperly had additional evidence added to it that should have been done through affidavit. Insist on an original document.

Do you have unaltered copies of any of these documents? Serve them in your request instead. Mention that in your reply - see line # XX of applicant/respondent's request to admit dated (date XX)