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Everything posted by reverserguru

  1. Dang Be careful if you ask for the DVD Gia for christmas (she probably already knows Angelina is way naked in that movie)
  2. They usually file a certificate of service with the court along with the CM receipt stating they have served discovery requests. I wouldn't want to get caught lying.
  3. 14. The claim that the Defendant’s responses to the propounded Requests for Admission are insufficient is not properly brought as a Motion for Summary Judgment. Plaintiff has not moved the Court to determine the sufficiency of the Defendants answers. See 12 O.S. § 3236. (The party who has requested the admission may move to determine the sufficiency of the answers or objections.......) 15. The claim that the Defendants responses to the propounded Interrogatories are insufficient is not properly brought as a Motion for Summary Judgment, but as a Motion to Compel. See 12 O.S. § 3237. (A) (MOTION
  4. You will need to object and show the facts of the case are in dispute. I am pasting a sample below that me and chi collaborated on and this motion was granted and she won her case. It would need to be altered to your situation and your states rules of civil procedure. DEFENDANT’S RESPONSE AND OBJECTION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT Defendant, <name>, hereby responds and objects to the Motion for Summary Judgment filed by Plaintiff, <CA>. In support of said response and objection, Defendant shows the Court as follows: 1. Paragraph 1 of the Plaintiff’s Petition states t
  5. True, especially with happy endings TNP never cleans their ears
  6. Until Pacal's Doomsday Don't you see it all unraveling?
  7. Don't forget the account origination fee, annual fee, and monthly service charge.
  8. When I was I kid, we had a female mutt dog that would hump your leg. Her name was Buttons.
  9. False, politics piss me off so why would I pay for it TNP likes David Bowie in spandex
  10. Mine supposedly died of food poisoning in office.
  11. "GM says the average UAW laborer makes $29.78 per hour, while Toyota says it pays about $30 per hour. But the unionized factories have far higher benefit costs. GM says its total hourly labor costs are now $69, including wages, pensions and health care for active workers, plus the pension and health care costs of more than 432,000 retirees and spouses. Toyota says its total costs are around $48." And that is just direct employee cost and probably nowhere near the actual shop rate on cost per hour and doesn't include all the salary related overhead, other indirect material costs managment, and
  12. congrats, but I'm related to a president
  13. I got one today from "my" girl in Peru. I love it, especially the homeade ones.
  14. I asked a guy at work today what kind of cars they drive in his home country (Belarus). It was a type of chevy that looks like a jeep that was the most popular. I don't think the cars they sell in other countries are the same they sell in the US. I have bought 2 dodges (caravan and dakota) and have been burned twice by poor quality. I wonder where the Toyota's being recalled were built? They do have US plants now that they are in NASCAR. I have also bought 1 Nissan (280zx) and 1 Honda (civic), both of which went over 300,000 miles. Looks like the deal is in stalemate anyway. One side wants cza
  15. Or vise versa, sort of Clay Center hunter shoots 27-point doe BY MICHAEL PEARCE The Wichita Eagle Courtesy photo Mike Smith of Clay Center thought he had shot the buck of a lifetime when he walked up on this 27-pointer on Dec. 3. He found out it was an antlered doe. Everything seemed perfect for Mike Smith. His scouting, stand location and shot were all on. The whitetail wore the kind of 27-point, gnarly non-typical rack most hunters only dream about. But something totally expected was missing. "When I rolled it over there was nothing male-
  16. I don't get choked up often, but the guy from San Diego whose house was hit by the F/A18 is on my list. Despite devastating loss, he is forgiving and understanding.
  17. He has been putting his foot in his mouth since he ran of Jimmy Johnson, not to mention meddling in the draft picks. I guess thats what billionaires get to do though.
  18. It's actually not greenpeace, they just watch and report. This is one of the greenpeace founders who got kicked out for his tactics. I wonder if they'd be so brave if it was Russian whalers.