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About needahand

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  1. I certainly agree- and I'd like to pm you the answer regarding the JDB if that's okay? Otherwise, I have the feeling they will wait until the last allowable minute to produce an affidavit which looks like is 10 days before trial. That doesn't leave me any time to consider much, I am sure that is their preference!
  2. Also they named one more witness...they reserved the right to call me. In the joint pre trial memorandum I named no witness. Do you think I should have reserved the right to call the witness they named also?
  3. Thank you very much BV80! I have researched the rules on biz records and have a decent grip on those, but not the exception and not from higher court rulings so will get on that. Otherwise they haven't provided anything to support their claims. The witness was named as the keepr of records or an unnamed alternative for the jdb testifying on the assignment and how they determined the $. I am feeling pretty helpless but ultimately, is the only thing I can do is to research these rulings until they produce their affadavit? Looks like they can wait until 10 days before trial to do that. Thank
  4. Hello, I am wondering, if you don't have this "plea for jurisdiction" and the jdb just says "we purchased the debt" with nothing attached, than what is the next course of action? Thanks
  5. Hi, I have been reading this thread and feel like this seems to be a difficult part of litigation which I don't understand. Can either of you posting here recommend a thread on this board to start understanding more basics on what to do in regards to calling witnesses, objecting to witness testimony,affadavits, business record and exception to hearsay rule? I am wondering if I need to address who a jdb has for witnesses in a pretrial memorandum? Should I reserve the right to have that party as my witness? Hope I don't interrupt your discussion too much with my question but you both seem to b
  6. Thank you for your helpful response. I am going to guess that I may get the discovery soon. Just a guess. But, I know that if I do get it, will definitely be partial.
  7. bump. help. any info on defense of breach of contract, please?
  8. Emm...thanks for the like, but I was wrong and I will not make additional discovery requests within timeframe allowed by court. Plaintiff has not responded to my requests for docs in the timeline either. So I am reading on rules on motions in limine. Lame excuses from them in meet & confer. They will send a partial discovery response. Perhaps I would best be served by a motion to reopen discovery. I don't see how a motion to compel helps me much. How could I effectively request admissions or interrogs without a lick of info. Am a little lost, but I know will prevail with all these br
  9. Thanks both of you! I think I will be okay, just going to make it. And no trial date yet.
  10. How do I find out? I cannot find anywhere in Mass rules
  11. Oh my goodness Savoir, thank you so much!! I have been worried about that! Have a good day
  12. Thanks much-- Got to wait till Monday when I have a printer though :/ Do you have any idea on my last paragraph at all? thanks again