ectotherm

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About ectotherm

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  1. Is subpoena preferred over 1987b even when dealing with OC?? Would appreciate any opinion or past experience.
  2. The declarant/affiant states they are a Asst.VP for the OC. Wouldn't 1987b apply then? The ccp98 includes copies of statements, and claims the typical personal knowledge of acct. Affiant states available for service of process, care of Attorney address.
  3. Hello, Thanks to all for your help. Just to update got CCP98. Should I use 1987b? Used on before on an affiant and got dismissal. Any better suggestions?
  4. Thanks to everyone who has helped me. Here is the latest: After CMC,Trial set for next year. What should be done in the mean time?
  5. I would like to thank everyone who helped with ROG's. The posts and PM's were greatly appreciated. However, I did send BOP as suggested and the response to BOP was "The attached copies of such printouts of monthly statements as are located after a reasonable and diligent search are provided in response to Defendant's Demand for BOP. Discovery and investigation are continuing." Should I send meet and confer letter now. BOP sent 25 days ago.
  6. Thank you Admin for taking the time to review. So I will use the template Seadragon was kind enough to share and send them to Plaintiff.
  7. Here are updated responses to admissions. Please let me know if these are ok or need editing. Thank you in advance for your input. 1) . Without waiving objection; Responding Party lacks information or knowledge to admit or deny this request. Responding Party made a reasonable inquiry concerning the matter in the request; however, pertinent documents have not yet been produced by the Plaintiff and thus probity of the requested information is speculative. 2) Without waiving objection; Responding Party lacks information or knowledge to admit or deny this request due to that it is overly broa
  8. Is this better? 2: State in detail all facts upon which YOU base your Denial in YOUR Answer/General Denial to PLAINTIFF’s COMPLAINT. Do not simply refer to your Answer/General Denial. RESPONSE - Without waiving objection, premature given that the parties are in the midst of discovery and pertinent documents have not yet been produced by the Plaintiff. Defendant upon completion of discovery with the Plaintiff, reserves the right to update this answer to this interrogatory at a later time
  9. BrunoTheJDBkiller are you referring to interagatory # 2? If so I will reword it. Thanks for the feedback
  10. Thanks for the discovery info Seadragon! Yes, I did send BOP and : The response to BOP was "The attached copies of such printouts of monthly statements as are located after a reasonable and diligent search are provided in response to Defendant's Demand for BOP. Discovery and investigation are continuing." Should I send meet and confer letter?