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freddiemac last won the day on January 18 2012

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About freddiemac

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  1. After I filed my answer, the court gave plaintiff 30 days to assign our matter to a case manager and has failed to do so. can i file a request for default judgement? Also plaintiff has failed to respond to my counterclaims so can I file a request for default judgement for that as well?
  2. The Colorado Jury Instruction book is a great wealth of info! It is cut and dry as far as the elements you need for various issues. From what I have found you have to buy it- i got an old copy off ofamazon for $24 Here is a free downloadable one for the State of California-
  3. Plaintiff: collection angency v. Case # Defendant(s): me and him Answer to Complaint, Defenses and Counterclaims , Defendant(s), deposes and says that the following statement is true and correct to the best of my knowledge and belief: In response to paragraph 1 and 4 of the complaint, Admit In response to paragraph 2 Defendant(s) Admit Defendant has demanded a Jury Trial and the Jury fee has been paid to the court. Factual allegations: In response to Paragraph 3 of the complaint, Defendants do not have knowledge or information sufficient to form a belief as to the truth of
  4. Thanks! Seadragon if it wasn't for YOU.......I would be in this forum- kicking rocks! I didn't end up appealing the trial. However the Court is supposed to be deciding on the attorney fees and I think I have a heck of an argument for an appeal when the dud decision is rendered. what do you think? In better news..... my recusal was GRANTED! Well it wasn't really a recusal per say, I filed my most recient answer to the summons and complaint (same retarded collection agency is the plaintiff and same birth) into district court by claiming jurisdictional limits on my counterclaims. Do you
  5. Totally awesome thankyou! They missed the statute of limitations because they were suing me and they didn't want to get bumped to district court. My state has no necessities doctrine.
  6. We are talking about a live birth, however were talking about care I recieved while I was pregnant. We are also talking about a very crooked collection agency and a crooked hospital billing department. I need some defenses. These guys are outside the statute of limitations. Ps if this is what u say, then why didn't these guys sue my husband to begin with? they new he was the only one with a job. I am the only person who has ever brought them to task. I objected to the last complaint based upon improper service and a dud notary. While the court begged plaintiff for a response and tossed out my
  7. This is not a community property state so those rules do not apply. These guys sued us under a very vague statute. I only brought up the baby as a fetus because they named my husband as responsible to pay for my care that I had while I was pregnant. How did the last case turn out- I didn't say? It went great! I thought anyway. It was my first pro se jury trial. I posted on this forum during it. come to think of it- the only trial I have ever been too. yeah looking back I should have at least found a trial to sit in on. But then I might have had cold feet. You know they say in Aikido that a whi
  8. Ps plaintiff did submit a fee request for just over 14 grand. Some of my arguments for why they should not get it were: Colorado follows what is commonly referred to as the American rule, which provides that in the case of a breach of contract lawsuit, attorney fees are not recoverable. See Agritrack Inc v Dejohn Housemoving Inc. 25P2d1187 (colo. 2001) This case is no different. According to testimony this Court heard by Hospital representative at trial, collection agency is not entitled to collect attorney fees. The wording in the contract signed by defendant did not allow room for assignmen
  9. So I have had this attorney fees hearing continued for months now. Each hearing the plaintiff doesn't show and it gets continued. Is there something I can say to object to the continuance of this attorney fee's hearing? along the lines of a sj (in my favor) for noshow? Each date the Judge goes through the bs of "well I don't know that plaintiff new of this hearing so I'll continue it a couple more weeks" I have proof that this court sent out notices prior to the last hearing but it didn't do any good
  10. Is this a jury trial? if so I would say that the jury determines credibility and due to the nature of these lies.....the jury needs to see the witness! If the court allows the witness to testify by telephone i would put the phone on the witness stand and cry foul. Did you get a continuance?
  11. Husband has been sued for my medical debt The same collection agency that I had a jury trial with a few months ago has just sued me and my husband over my hospital stay for a pre-birth pregnancy complication as well as the birth of my son (different dates). I need help with the answer please. I signed the commitment to pay for the hospital bills and my husband did not sign any document. The complaint states that the accounts were expenses of the family for which husband and wife are liable. The complaint it self is very short. Basically it states the addy is my house, defendants r not in t
  12. he ordered a max of 20 interrogatories and/or requests for documents
  13. The court ordered them to comply with discovery prior to trial. I made a big deal of how badly I needed discovery so that I could properly defend myself. They granted 20 interrogatories.............Would I still have needed a Motion to compel prior to trial?