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Gristle last won the day on January 15 2017

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  1. Question; would you recommend I supplement my answers that I already sent back and add; objecting to the term "incident"? (Using the above recommendations) Thanks again for ALL the great feedback, if you only knew how much it meant to me, you all have been amazing!
  2. Thanks, very good stuff! I sent out my responses. However since I have (2) suits going at the same time and I just received those RFA's and ROG's I will add that info on that one. Cavalry is gonna be sorry they came after us...and by us I mean you all...thank you so very much for all the help!
  3. Question; Do I file my answer to RFA'S and ROG's with the court? I know I do proof of service but can't remeber if I need to file as well. THANKS for the HELP!!
  4. OK, here are my reponses to the Form Interrogatories please let me know what you think (all help is greatly appreciated!!) I intend to mail tomorrow; Responding Party: DEFENDANT ME REQUEST FOR SPECIAL INTERROGATORIES (SET NO.1) Requesting Party: PLANTIFF CAVALRY SPV I, as assignee of CITIBANK, N.A., ME, the defendant in the above cause, responds as follows to the first set of Special Interrogatories of Plaintiff, Cavalry SPV I, as assignee of CITIBANK, N.A.: 101.1: State the name, Address, telephone number, and relationship to you each person who prepared
  5. Need some last minute help on answering Interrogatories before I post for review, here are the questions I'm stuck on; 1. State the name and address, telephone number and relationship to you of each person who prepared or assisted in the preparation of the responses to these interrogatories. Intended answer; me. 2. State your name, any other names by which you have been known and your address. Intended answer my name and address. 3. State your date and place of birth. Answer? 4.State as the time of the incident, your driver's license number, the state of issu
  6. OK everyone, here's what I have so far for RFA's. Please let me know your thoughts. I will be working finishing up my answers to interrogatories this week and will post once finished. As always thank you so much for your help and support!! Responding Party: DEFENDANT Me REQUEST FOR ADMISSION SET NO.1 Requesting Party: PLANTIFF CAVALRY SPV I, as assignee of CITIBANK, N.A., Me, the defendant in the above cause, responds as follows to the first set of Requests for Admission of Plaintiff, Cavalry SPV I, as assignee of CITIBANK, N.A.: 1. Admit t
  7. Great stuff!! Thank you so much!! I went to Case Management this morning, trial set for Nov. 13. The stand in attorney for Winn is a "regular" meaning she heard all 10 other cases before mine (for all kinds of different Plantiffs). She's been in the area since late 90's. She's an old pro that knew all the other attorneys and judge. She was very cordial. However, I know she is not the one putting the case together so I just need to do my part!
  8. The cover page in response to my BOP stated the following; Plantiff's complaint filed on or about November 7, 2016 is for an account stated cause of action, in addition, money lent. In Ahlin v. Crescent Commercial Corp. (1950) 100 Cal. App. 2d, the Court held that in action for an Account Stated, the Defendant is not entitled to a Bill of Particulars, since it is not necessary to prove the items of the account on which the account stated is based. (Also held in Distefano v. Hall (1963) 218 Cal. App. 2d 675, 677.) Plantiff, Cavalry SPV I, LLC, as assignee of Citibank N.A.'s response to you
  9. Given their response to my BOP and after reading 1111girls thread again; what should I send them due to their inadequate response?
  10. Here is how they responded to my BOP; Plantiff objects to each and every demand to the extent that it calls for a response evidencing or embodying confidential communications between Plantiff and their attorney on the grounds that such communications are protected by attorney client privilege. Plantiff objects to each and every demand to the extent that it calls for a response evidencing or embodying the work product of his attorney. Plantiff has not completed his investigation of the facts relating to this case, has not completed his discovery in this case and has not completed
  11. One more question; as I prepare my responses should I be sending the Plantiff anything? All I've sent so far is BOP and received their cut and paste response. I've read to lay low until I received the interrogatories. Now that they are here should I be requesting documents and push for a better response to my BOP? Thanks again for your help!!
  12. Hello everyone, still moving along. I have a Case Management hearing on Tuesday and lo and behold this past Friday I finally received the interrogatories and special interrogatories (post marked April 3 and received April 7). They all look on par with what has been posted on other threads. I will prepare my answers using the great info here and post for review this next weekend. As I understand I have 30 days (plus 5) so if I mail it by May 1 I should be good correct? Calvary sent 10 consecutive billing statements and a blanket contract agreement that looks like they printed off a websit
  13. Happy New Year, I hope everyone had a great Holiday season! I received my response to my request for Bill of Particulars and it is quite comical, similar to what others have posted here. I will post later for all to get a good laugh. In a nut shell they sent 3 random bills and stated all the "attorney client privilege" garbage. The best part as I've mentioned before I have two cases; well they responded to both in the same envelope but the laughable part is they used the exact same cover sheet for both; same case number everything. Someone at Winn must of caught it after the attorney signed it
  14. Filed denial and POS today. Been researching my local court cases with Cavalry, looks very promising, 100's of cases in past 18months, lots of missing paper work and dismissal for improper service/lacking documentation. I'll post the exact verbage this week from the minutes, perhaps someone can interpret. Lots of default judgements and about 30%ish dismissal only couple went to trial. Also looked up the local attorney Winn sends on their behalf, passed the bar in 1990 so has experience. Saw one case dropped quick when attorney for the defendant requested a jury trial and it was granted. No wor