Weltman Request for Production

Please produce all assignment, transfer or sales documents showing only the specific sale transfer or assignment of the debt and please do not just point to a pool of numerous debts not part of the lawsuit here. Defendant request all the assignment, transfers and/or sale documents evidencing every sale , assignment or transfer of the specific debt of " " only.

Weltman Response: Plaaintiff is the original creditor for this account. On May 18, 2025, Discover Bank merged into and became part of CapitalOne, N.A. ("CONA"). As a result of this merger, Discover Bank no longer exist and CONA continues to operate as the sole surviving entity. The National Bank Act provides that the surviving entity in a merger of a state into a national bank is "deemed to be the same corporation as each bank or banking association participating in the merger," and that all "rights,franchises, and interests of the individual merging banks or banking associations in and to every type of property (real,personal,and mixed) and and choses in action shall be transferred to and vested in" the surviving entity. 12 U.S.C. Sec 215a(e). Thus, in accordance with the National Bank Act, CONA holds all of the same property rights and interests that Discover Bank had prior to the merger, including but not limited to the rights to existing Discover Bank accounts and receivables, and is Discover Bank's successor-in-interest in and pending litigation and matters before any Federal or state cout. See Merger attached as Exhibit C.

Wanting any thoughts on their response. Also, the used This request is vague, irrelevant , overly broad, unduly burdensome, and not reasonalbly calculated to lead to the discovery of admissible evidence. In each request for documents.