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About notgoingdown1

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  1. Oh yeah, this has occurred to me, really I left that courtroom with the distinct impression that the judge fully expected me to appeal, he is the only judge in a large area, so I know he knows these cases but from What I've researched no one has really fought them this far in his courtroom. I see you are in Oklahoma, don't Suppose you have much appeal experience here?! Lol but I've got loads of other info if you need it.
  2. Okie dokie, well looks like I know where to read in the statutes now oh well I suppose you fine folks here at cic will help along the way screw em, Oklahoma needs some case precedent anyways!
  3. Court went well, They presented their motion, I argued bringing up all the key issues that created a material issue yada yada. I'll post my opposition shortly. The judge asked them to explain why my name wasn't referenced in the bills of sale. The lawyer went into this very boring explaination of the ins and outs of junk debt buying and how that's simply how its done etc. The judge ruled in their favor. As he did so, he told me how impressed he was will my filings and motions etc (THANKS TO CIC and then told me he didn't expect me to agree with his ruling. He spent the next 30 minutes explain
  4. It might help if you posted the MSJ (redacted of course with no personal info posting) so that others on this board can be more helpful.
  5. DEFENDANT’S SECOND SET OF REQUESTS FOR ADMISSIONS TO THE PLAINTIFF FAILURE TO TIMELY RESPOND TO REQUESTS FOR ADMISSIONS IN COMPLIANCE WITH (your state’s statute) SHALL RESULT IN EACH MATTER BEING ADMITTED BY YOU AND NOT SUBJECT TO FURTHER DISPUTE. COMES NOW, Defendant xxxxxxxxx, in pro se, pursuant to (your state’s statute), and submits the following Request for Admissions to the Plaintiff, JDB, by and through its attorneys XXXXXXXXXX, to be responded fully, separately, under oath and to be delivered to the Defendant within thirty (30) days from the date of service hereof. DEFINITIONS The fo
  6. hmmmm, could be unlimited then. I'll post those discovery questions and you can see if you want to use any of them.
  7. your state should have rules for civil procedure somewhere on the internet. In my state if I google oklahoma court records I find the link to the Oklahoma supreme court network, from there after a bit of searching I found my state's civil procedure, then you'll find discovery under that. The rule 56.01 looks like a good start but you need to know how many you can send. You need to have access to your state's RCP (RULES) if you plan on fighting this OMG that was just too easy haha, one search, first link:: Rules of Civil Procedure - Rules Governing Civil Procedure in the Circuit Courts try thi
  8. Have you used all your discovery? In my state you can send a total of 30 admins 30 rogs and 30 pod's , so what are your states rules? The reason I ask is because I have some I can post for you that coltfan helped create. As far as the admins I haven't answered I'll take a look tomorrow at work, basically from what I've learned you really want to get your objections in on anything to do with standing. Ive had two cases so far. In one they never even sent me discovery they dismissed with prejudice after missin their deadline to answer my discovery... The other one has been a little tougher.
  9. NEVER EVER EVER concede to Plaintiff's standing. Maybe I missed it, who is the Plaintiff? Please take my answers with a grain of salt, as I'm a newbie, I'm just practicing right now, but never ever concede standing to them. This is very similiar to how I answered my admissions in one of my cases. Have you sent discovery yet?
  10. I'm curious about this as well, I am over the three year SOL now, there is another lawsuit filed but not served yet floating around out there. With my answer I think I'll file a MTD for the three year SOL and we can see how that goes
  11. Has anyone ever told you that you have a way with words?!!! You just made my day AGAIN Coltfan
  12. That is what I have heard as well BV80 and Bruno. This okcdebtfighter has said that they successfully filed and won a motion to compel arbitration well into the litigation phase of the case (ie when the other side filed a MSJ) so I'd like to hear their full story, for entertainment value, and maybe it could be an ace.....