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About Caligirl14

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  1. Thank you Calawyer so very much!! These are great. I will check my notes on the one citation. I am pretty anxious about trial, and still, having the case law and being prepared feels great. I really appreciate all the help and feedback on this forum. : ) BV80 - that you for your input. You are right, they huffed and puffed in their answers to admissions. They denied having an agreement, but then said it didn't matter legally speaking. They also claimed that they after a diligent search and effort, they "believed" that the original statements and all accounting was with the original creditor
  2. We go to trial in a week from today. LVNV Funding did not respond to discovery, so we had to file a motion to compel admissions and req. production of docs. LVNV funding finally responded last week, but simply gave us the same paperwork they originally provided when we asked for a Bill of Particulars back in December - nothing new, except the answers formulated admit, deny etc. The exhibits are the same. They have provided no signed agreement which they reference in their complaint, no contract, no statements, and no itemization of account to show how they came up with the amount owed - we don
  3. Good afternoon. We are sending the Motion to Compel and Motion to deem matters admitted allowing 16 + 5 days for potential hearing date. For the Proof of Service - Is it okay to simply have one Proof of Service that states they are sending both motions and mail them in the same envelope? Or, do we need a Proof of Service for each motion? Is it okay to use a 81/2 by 11 sheet with "Exhibit A" in the center to separate the Exhibit from the Motion? Our trial date is 6/6/14. Mailing when we get back in town this week will set the hearing date of May 2, 2014 at the soonest. I was also reading in
  4. Thanks so much doublethefun9941! I will see if I can upload as pdf right now. This is the site for saclaw that was so helpful for this CA paperwork: I realize that I need to personalize and make 4 copies - one of which requires the cardboard Exhibit A and the others simply with the cover page "exhibit A". In our county, we must file at least 16 days before the hearing date. We also have trial coming up on 6/6/14. This is the motion to compel draft. Do I need to add proof of service page? Any feedback is welcome and appr
  5. Thank you very much for your input. I have prepared a Motion to Compel production and a motion to deem admitted. I wish there was a way to upload them here for feedback and assistance to others. I spent a lot of time on the forums and researching google to create these docs. I also found that the website was really useful with step by step guide and template forms. Is there anyway to upload these 2 docs? I also tried to copy and paste one of them into this thread, and can't do it. I would love to share for both feedback and assistance. Could someone please advise? When I try to
  6. Hi- These forums have been extremely helpful as we've prepared defense paperwork on what appears to be junk debt buying by LVNV Funding represented by Nelson Kennard in Sacramento, CA. We responded to their discovery req. for Adm, Prod of Docs and Form Interrog. with help from many on this forum. We've met for CM and Settlement Conf. and trial date is set for 6/6/14. (At the CM and Settlement Conf., Nelson& Kennard sent a local atty who was not familiar with the case and appeared confused. He did agree to the trial date) We sent our own Discovery request on 12/31/13 and Plaintiff has no