Lawsuit Question

I previously posted. Being sued by creditor for credit card debt. I have answered summons/complaint. I was served with these form interrogatories and was hoping there is a laywer here or anyone with past experience who can help me answer these questions.

FYI. Debt wasn't properly validated. They only sent me random copies of statements as debt validation.

Anyhow the questions asked on the interrogatories that I am unsure how to answer are


State why you are not responsible in whole or part for plaintiff's damage.

Identify all documents that are part of the agreement and for each state the name,address, and phone number of person who has each document.

state each part of the agreement not in writing, the name and address of each person agreeing to that provision and the date that part of agreement was made.

state each modification not in writing and the date and the name,address of person agreeing to the modification.

identify each agreement excused and state why performance was excused.

identify ech agreement terminated by mutual agreement and state why it was terminated

identify each unenforceable agreement and state the facts upon which your answer is based on.


Also, does anyone know if I have to file with the court these answer to the form interrogatories and the request for admission/production of documents?

Thank you for any help. It is very much appreciated.