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About mommamia3

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    Hoping to bring 'em down

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  1. Yes, you want/need to respond to CCP96 and if you are only using what they have provided to you in discovery just state that in your response. It's a little something I learned from calawyer and it definitely rattles them. And yes, definitely subpoena their witness!
  2. in my case they made errors like this ALL the time. Keep documenting them, they may come in handy later!
  3. Hi there! Sorry for the late response. The Case Management Conference is just a formality where both sides go in front of the Judge and let them know that discovery is progressing. Discovery is not expected to be completed by the CMC. I would mention that Plaintiff's Case Management Statement mentions a desposition that you know nothing about. I would also mention or put in your statement if the BOP is outstanding (is it?). If I recall correctly you did request a Bill of Particulars but their response was insufficient. Please let me know more specifically how I can help !
  4. I am sure calawyer has already been in touch with you but just in case, don't freak. Even with my little bit of knowledge I know they can't do what they are suggesting. There are timeframes on discovery for instance and they can't produce documents at the last minute that you haven't seen prior to trial. That is the purpose of discovery, no surprises! Be ready with your arsenal of objections in case they attempt to introduce ANY documents, let alone anything you haven't seen prior to trial. Curious who the witnesses are they are thinking of bringing. PM me with that if you get a chance.
  5. to calawyer's post: Good idea to double check though since your case is UNlimited, most of them on here are limited.
  6. A BOP is NOT part of discovery rather it is treated as an amplification of the pleadings therefore you can request both. You want to look up posts by calawyer who has an excellent post about exactly what you are asking. You want to send your BOP request immediately and, by law, they have 10 days to comply. Once you get a reply to that you have an idea what 'evidence' they currently have in their possession and you can then request your discovery from there. It was recommended to me only asking for RFAs and PODs as you will usually get all objections to ROGS. If I can find the link for cal
  7. they coudn't get my account straight either. It was a 16 digit number than it was a 14 digit number. It was 16 digits in one order than it was a 16 digits in another order. They were beyond sloppy in my case. Unfortunately, you have to play the game. There is no silver bullet to get them to go away. Just keep building your case, they will do themselves in.
  8. You are spelling it incorrectly, it is Vinhnee. The case is regarding business records exceptions. Google Vinhnee and it will come up !
  9. There is a link regarding debt validation right at the top of this board which includes sample debt validation letters. Forget that, I was told it is old and outdated.
  10. these lawyers are very sloppy. You won't get them to go away easily but keep plugging along and they will do themselves in. Sorry there isn't a magic bullet. I hoped and hoped and hoped too but had to go right up to trial with them. Any questions pm me.
  11. What about the letter they have on the link wen you first login to this board that says "debt validation". That letter is far more detailed. Is it not appropriate?
  12. the second creepiest of creeps, CACH!
  13. the ccp96: Do you have any of your own witnesses, evidence, photos, etc. that you are going to use? OR Do you intend to just question their witness and use their documents (or lack of) against them?