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Everything posted by james24

  1. is it too late to try to use this to revisit the decision against me 2 years ago?
  2. I think that was it in my case. But i guess court of appeal ruling is final.
  3. This would have helped so many people but at least it will help more in who are undergoing this nightmare from JDB. Will this still help people who lost court of appeals who had the same argument as target and rodgers? Or too late to do anything?
  4. What is the timeline to recover costs after judgment? Do i use MC-012 form (memorandum of costs) or JUD-100? Trial was dismissed March 20, 2015. Thank you!
  5. Thanks everyone for the support! Dont wanna go through this again. Now i will start the memorandum of costs!
  6. Well, there was no dismissal filed but the lawyer informed the court about the dismissal but still, i dont wanna take chances. You know JDBs! Thank you again everyone!
  7. Just finished thetrial. It was the same lawyer i fought against from CACH! Hehe. We remembered each other, reminisce how he got lucky coz the judge helped him. Thank you guys! Dismissed w/o prejudice.
  8. When i show up for tomorrow's trial, should i tell the judge that i am requesting for dismissal with prejudice? Coz right now it is too late to file something. Court clerk closes at 2pm and trial is at 8:30am tomorrow. I checked the dock, nothing was filed yet as far as the dismissal of the case.
  9. Haha. I just wish this was the result last time since it has a bigger amount. But at least i got this out of the way and hope that i will be able to help out others the way i was helped by people in this forum. Thank you guys!
  10. I read articles stating that self represented party can also file costs for having time off from work to be able to work on the case. I would like to include that too. Thank you!
  11. Just got fedex from jdb lawyer "request for dismissal" do i still have to show up for trial tomorrow (3/20)? What will be the next step or how to recover for my expenses? Thanks everyone.
  12. Inputs and suggestions please. Objection to CCP98. I will be filing it tomorrow 3/13 together with trial brief. Thank you all.
  13. Trial date march 20. When is the best day to send subpoena and file objection to ccp 98 and trial brief? Also, Objection to plaintiff's ccp 98 can be accepted rather than MIL or it has to come in the form/title of MIL? Thanks guys. Suggestions and help needed asap.
  14. Oh ok. So i will start the subpoena on march 2 at least 3 attempts. Then file my trial brief and MIL. As suggested before, is it ok to change the MIL to "Objection of defendant to plaintiff's CCP 98" as title of the document?
  15. I should still send subpoena to the address provided by the witness right? It is the jdb lawyer's office. To show court that i tried? Or should i send my MIL together with the trial brief as early as today feb 27? Thank you.
  16. After these corrections, trial brief should be ok to be sent out? Trial date is March 20. I will subpoena the declarant around march 2, then file Objection to the Ccp 98 after failed attempts to subpoena instead of MIL as suggested? Thank you guys.
  17. can i use this as argument for trustworthy? here is the link to the original affidavit of sale and the modified one is here. Can i put it my trial brief that since at the bottom of the document, it has electronic writing that says "version", can i argue that the AOS may be a template that they just fill out the blank spaces according to the information they have? and that the declarant doesn't have to go to notary public every time? can i show the judge that it can easily be modified by using my modified version as example? maybe it can help other cases as well so we can destroy the affidavit of sale. @calawyer @Seadragon @HomelessInCalifornia @Anon Amos @shellieh98 thanks guys my Trial Brief
  18. Just trying to get me meet deadlines. Although i pretty much have trial brief done. Just polishing it on the best words to use to present target v rocha. Because the first case i lost seemed to really have a good one but gave the judge a chance to getaway by not emphasizing on the very important parts. Thank you guys for the help. I guess i wont do continuance.
  19. I want to reschedule the trial. I tried to file motion and notice of motion for continuance with points of authorities and declaration, clerk said the title needs to be changed otherwise i will be charged $90 because the title indicates i am requesting to be heard by the judge so i can request for change of trial date.
  20. Hello, I am writing my trial brief, how can i best point out that the witness is using "in care of" address to receive the subpoena? I know CACH v Rodgers and Target V Rocha, i just want to make sure i hit the nail on the head. I want to win this case. also i am looking at the bill of sale, they sent 3 copies but each has signatures of people. i mean, shouldn't a contract be signed by signatories in one document and not separately? what is the best way to point out trust worthiness of the document. here is the link to the Bill of Sale. Trial date is March 20, what date can i send the subpoena? is it 20 calendar days before trial or 20 business days before trial. thank you very much! @calawyer @Seadragon @Anon Amos @HomelessInCalifornia @shellieh98
  21. What's the best way to answer these? 11. Did you receive periodic statements from GE capital retail bank regarding the credit account? 12. State approximate date of your last payment to GE capital retail bank on the credit account. 13. Have you ever corresponded with GE capital retail bank in writing regarding the credit account. 14. Have you ever corresponded with portfolio recovery Associates in writing regarding the credit account? 15. State all facts upon which you base your denial of the complaint in this action. 16. State all facts upon which you base each affirmative defenses to the complaint in this action.
  22. Shoot! trial date is March 24. I counted, less than 30 calendar days before trial already for ccp 96. What will be the title heading for the MIL? OBJECTION TO CCP 98? Lawyer's office is less than 150miles. but that will be receiving subpoena in behalf, like they always do. Definitely a different judge. I am trying to retrace my steps so whatever i did correct on this case that made me win can be a blueprint just like @astmedics How I beat midland post, only this can be the updated version with Target vs rocha and rodgers v cache.
  23. @Anon Amos, i am gonna work on @shellieh98 suggested then submit all my response together with ccp 96 today because they sent a letter that they should have it by Feb 16. Since I have the ccp98, i should start working on MIL and Declaration in support of it. Any new inputs since you did yours? maybe like citing new cases that beat JDBs? Thank you!
  24. My plan today is to send my responses together with ccp 96 although i just got their ccp 98 yesterday. Planning to send subpoena for the witness who gave the lawyers office in san jose ca. Any other suggestions? I got exhausted on the last battle that i kinda forgot the steps i took coz i dragged them up to the appeals. Thanks people here!
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