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Everything posted by sadinca

  1. Thanks @RyanEX I was just reading your threat. was your declarant also a jdb employee?
  2. in the mean time still preparing. received ccp98 from Plaintiff. thus far all the objections to CCP98s declarations ive seen posted around are for defendants receiving ccp98s from declarants from another state, so rocha and rogers case were great for them. unlucky for us, the declarant in this CCP 98 is a "legal specialist" by MCM. so, I do not think those would apply to our case. can anyone post a link to an objection of MIL prepared relating to an employee of plaintiff to use as an example? Also, declarations states that he will be available for service 20days prior to trial at Chico, CA; Fair Oaks, CA; San Jose, CA; Visalia CA; all those of course up Northern CA. also available (c/o) in Commerce, CA; and of course two addresses in San Diego, Midland and Encore. can we subpoena the Commerce address, since its the closes to my residence?
  3. Thank you seadragon, still tying to convince her.
  4. here you go. http://www.privacyrights.org/data-breach-asc?title=chase search for the alleged OC creditor and if you find any security breaches you can question the witness regarding his knowledge of any security breach. after he says no and lies through his/her teeth, you can bring the fact that there has been any security breaches. I do not know if this could open a can of worms, somehow. anyone?
  5. I just thought abt something. I found my wifes oc there. If those security breaches are mentuoned during trial would they be considered hearsay?
  6. I asked because I found a website that lists all security breaches repoted. This includes banks, hospitals, small business,; etc. Maybe you can find GE capital there and include it in your questioning. Unfortunately, I found no jdb there.
  7. if they are withdrawing the CCP 98, and actually bringing a live witness. does that mean that they have to bring that person named on the ccp98? or can they get away by just bringing anyone else? if so, should she receive something stating who that witness would be and what the witness will be testifying about?? for the sake of future readers. if the trial is ever set for continuance, as in this case, should the defendant serve another ccp96 on plaintiff?
  8. and thank you for that suggestion. does any one here can recommend a consumer attorney in the OC area?
  9. do you happen to have a link to that video? I tried looking for one but I only got hearings and lots of ads.
  10. We did sit on One trial, but there was no much of a trial. He defendant wasnt prepared to defend
  11. Thank you guys! I will continue putting pressure on them, and we'll see how everything turns out. the most depressing thing, in her part, is that trial is the same day as our son's 2nd b-day. could not have landed on a more inappropriate day.
  12. 96 and 98 are calculated in regular days. Motions documents are filed using COURT days.
  13. Thank you guys! I now know her member name in these forums. we are now 33 days away from trial. we served CCP 96 earlier last week on plaintiff (44 days away from trial), i believe that plaintiff must serve their ccp98 at least 30 days before trial. I keep encouraging to push, we trained and practiced for the motion, but when the time kept she froze, i guess as @strings mentions "court-phobia." now that the JDB knows this... why would they even try to settle before trial when they now know she wont be able to defend herself the day of? even after subpoenaing the 98 declarant, and filing oppositions?
  14. Hello everyone, I got out of court about 2 hours ago, since my wife had a Motion to Compel Hearing, this morning. unfortunately, despite all our preparations and going over and over the materials she was requesting and the reason of importance, she blanked out during the motion, due to the pressure and nervousness and the judge denied the motion. needless to say, she took this defeat very hard and she now just wants to give up. since she feels the same thing will happen during trial. she's been getting a lot of help from here, I've been reading all the printout she has brought home, and I am very familiar with her case. but what can I do if she refuses to proceed. what are the chances that JDB would try to settle this before trial now that they MTC was denied? any suggestions, any one.
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