QUESTIONS FOR DEPOSITION IN A BILL COLLECTION MATTER

1. Please state your full name for the record. 2. Who is your current employer? 3. Who was your employer at the time of this action? 4. Do you know if your employer, at the time this action was commenced up to and including the current date, was and is current with its corporate charter, business license, taxes, insurances, and other such statutory requirements? 5. What is your current job title? 6. What was your job title at the time of the commencement of this action? 7. What was your involvement with the account specific to this matter? 8. Did you transact payments? 9. Did you issue monthly statements? 10. Did you make regular reviews of this account? 11. Did you have any contact with the Defendant? 12. 13. Do you have authorization from any principal from your company to engage in contractual relations with other entities? 14. What are the types of contracts that you are authorized to enter into? 15. Who is the designated party within your company that granted you authority to engage in these contractual arrangements? 16. Do you have authorization from your employer to specifically engage attorneys in the name of your employer? 17. Did you retain the law firm or attorney specific to this matter? 18. Who signed the contract on behalf of the law firm or attorney specific to this matter? 19. Do you know if they have proper authority to enter into these types of agreements? 20. What is the scope of authorities granted by your employer to the law firm or attorney specific to this matter? 21. How did you validate that the law firm operating at your behest in this matter was statutorily compliant as an entity within this state?

22. How did you validate that any attorney managing this case was statutorily compliant as an attorney within this state? 23. Did you verify that the attorney in this matter at your behest has an Oath of Office? 24. Did you verify that the attorney assisting your employer in this matter has a good faith surety bond or the equivalent? 25. Did you verify that the attorney assisting your employer in this matter has current and valid malpractice insurance? 26. What is the normal course of action of your employer per their policy when a debtor is unable to make their regular payments on an account? 27. Was the account in this matter charged off? 28. Was or did your employer receive an insurance benefit as a result of this account being charged off? 29. Was or did your employer receive a tax benefit for demonstrating that this account was charged off? 30. Was this account sold or similarly transferred to another party? 31. If yes, to whom, at what cost, and when was this account sold or similarly transferred? 32. Was this account sold or similarly transferred to this law firm or this attorney? 33. If yes, when was this account sold or similarly transferred to this law firm? 34. Who within the ranks of your employer authorized this sale or transfer? 35. What obligation does the alleged debtor in this matter have to your employer at this point?