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About mkhal

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  1. Bunovitch, I feel you. I just lost today as well and with the same disgusting manner, I got cut off half way speaking by the judge and she said she's gonna sign the motion. Sucks.
  2. So I went to court today, filed my paperwork for my dueling affidavit and got my assed handed to me. The judge said they had standing and I outright denied me saying they've proved standing in Washington State. So what do I do now? I owe them apparently 2600 dollars which is 3 times the amount of the original card in question.
  3. @hot in az, I looked at the Washington State rules of civil procedure and found this: c) Motion and Proceedings. The motion and any supporting affidavits, memoranda of law, or other documentation shall be filed and served not later than 28 calendar days before the hearing. I was served these documents on Friday 19th of July..just ten days before the hearing and they claimed they filed it with the court on 12th of July, which is not even 28 days before the hearing.. I put this as my first point in my summary because it states I have to respond 11 days before the hearing and I didnt even g
  4. @hot in az Okay I updated it so that you can see what I'm working with but again I don't understand what am I replying to in MOSJ, because I posted their motion statement in my initial post and it is very brief. But the initial account was not Chase it was washington Mutual which became Chase???. Honestly I don't know if this is a pre trial conference. All I got was a paper saying "Please take note that a hearing has been scheduled on Plaintiffs' Motion for Summary Judgement." Date: Monday July 29
  5. Also Huey, why did you use Delaware Civil Rules of Procedure 56(e) when you are in Oregon, please explain how that came to be so that I may research it. Thanks
  6. Thanks for all the great advice, so am I answering line by line the motion? Because I posted the motion above and it was very brief what they wrote to the court. @hot in az @hueypilot Secondly, in my counter affadavit, I can't find the affadavit rule in washington state courts civil procedures like you put in your Oregon state law huey, "pursuant to the laws of the state or Oregon and Oregon Rules of Civil Procedure 1E" All I found was this:
  7. Thanks Huey, You always provide great templates. I am going to create a draft here and attach it tonight.
  8. I know there are many templates on these forums for countering motions for summary judgement but I wanted to make sure my response was catered to my exact motion in Washington state. Please help me draft it here. I have a hearing in ten days and they sent me the motion stuff just at the tenth day. Just to get people up to date, got the summons, and the plaintiff discovery responded..denied all, sent my first half a$$ stuff back no original signed contract now they have sent me the motion for summary judgment.. Here is there motion: Comes now the plaintiff,
  9. @racecar, I don't see the card in there since it was an old WAMU account. They've sent all their motions and want to see me in court on July 29 and I have no idea what to do. I've already sent my first discovery in which they never sent the original contract, and sent a blacked out mass account bill of sale. I'm sending my counter affadavit on Monday and what else to do? Can someone please take a look at the bill of sale I attached so I can counter it. Thanks.
  10. Here is the Bill of sale they sent me. NOTE: I did not blacken anything out. This is how they sent it to the court. I couldn't believe this when I saw it. How is this legal?? scan0003.pdf
  11. So an update, since my first request for productions, they haven't been able to produce the original contract (As far as I've read, they probably never will be able to), and they produced some bill of sale between Chase and Midland with all the lines black inked out (I will post it later in the evening). However, I have one issue that is making me nervous. After these events took place and 30 days have lapsed since they haven't produced the original contract, they have been trying to contact me via phone(how they got my number I don't know), but some lady named christine leaves a message
  12. So after I sent my first request for admissions, it came back and Daniel Gordon said they are diligently searching for the original card agreement. When I requested all itemized statements showing how the account was up to 2500 they just sent some random statements they was all out of order and said they sent the charge off statements? When I asked for the bill of sale of the card agreement from Chase to Midland..I got a bill of sale with all the numbers any names etc crossed out in dark black ink?? Basically it is a Bill of Sale with no information on it besides a template. My que