How do we respond to an "Request for admission of facts", "request for prodution of documents & notice to produce to defendant"?

When your tooth hurts, would you get pliers and pull it yourself? When you break a bone, would you make your own cast? And when you get sued, would you file pleadings with no training as to how to do it? The answer to all three is "of course not." Defending a lawsuit on your own is almost a guaranteed way to lose, and theer are no do-overs. When you lose, and you're close at this stage, you'll face garnishments, bank account levies, liens on property, etc. You needed a lawyer a long time ago. Get one now to see if you have any realistic defense. If you don't the lawyer may be able to negotiate a settlement or get rid of the case in bankruptcy. Hurry, the motions you mention mean you are likely very close to losing.

Just to show you one example of how important it is to have an experienced lawyer help you in answering discovery: if you do not give a proper answer to certain discovery items, within certain strict time deadlines, it is treated as a matter of law by the court as though you entered admissions in favor of the other side. Then the other side does a motion for summary judgment, and you automatically lose the case without even having an opportunity to be heard in court. As the other attorneys said, you need an attorney yesterday, unless you can afford to lose.