• Content Count

  • Joined

  • Last visited

Community Reputation

10 Good

About NationalizetheBanks

  • Rank

Profile Fields

  • Location
  1. Dear All Sorry for the GREAT delay in coming back on this. So i have some NEWS to report. LVNV ....FOLDED.....and withdrew their case....they clearly saw we meant business and the expense for them to continue their pursuit (which in and of itself)may have been illegal) was going to be much more than they assumed...........thus they withdrew I will leave you with one final thought - Americans - the public - are highly brainwashed - our brothers, sisters, mothers and fathers - collectively have been indoctrincated into believing that things such as Canadian/European socialism, organicall
  2. I have: 1. Filed my Motions for More Definite Statement and Motion for Dismissal - which was filed before Answering the original Complaint - a must by Ohio law; and 2. Filed my Answer to Plaintiffs Interrogatories; and 3. Filed my Answer to Plaintiff's Complaint - which was due April 7th. After speaking with two attorneys in Ohio and others, everyone recommended I file the Answer to the Complaint before the due date whether the Judge had yet made her decision on my motions or not - better to be safe than sorry. Below are my Motions and Answer to Complaint... _____ 1. Motion for
  3. @rikkivs - here is my proposed Answer. Could you please add some Affirmative Defenses that make sense? I know them not having the Agreement I believe it one. Answer 1. As Defendant does not have sufficient information to respond to Plaintiff’s complaint, Defendant reserves all his rights and denies all allegations in Plaintiff’s complaint. 2. Specifically, regarding Paragraph 1 of Plaintiff’s complaint, Defendant has no knowledge as to whether Plaintiff is in fact the rightful duly vested owner of the claimed credit card account, and derived assets and liabilities, through Purchase as claim
  4. Question: Ohio Rules specifically state that a Motion for a More Definite Statement should be filed FIRST before an Answer to a Complaint is filed. Ok..that is easy to understand. So... why... once I have filed my Motion for a More Definite Statement....should I WAIT to file my Answer as is being recommended here and risk my Answer being filed after the current due date which is April 7, 2012? I can file my Answer the very next day and thus my Answer would be filed AFTER my Motion for a More Definite Statement but before the Judge has probably ruled on said Motion. I have not seen in the R
  5. @legaleagle - thanks for clarifying this...i will revert to my other version as I had updated mine to include both an object and denial. Regarding my question to he wanting me to Strike their Interrogatories Request? The Plaintiff has not filed for a Motion for Discovery....but did file a Plaintiff's Interrogatories......are they both construed as "Disovery"? I do not mind answering their Interrogatories as I don't have much if anything to say that is damaging to me. Thanks.
  6. @Xcalibur - The Plaintiff has not filed a Motion for Discovery. They have filed/sent me a "Plaintiff's Combined Interrogatories Request for Admissions and Request for Production of Documents" - is this what your referring to?
  7. @legaleagle - thank you - all changes have been made in my response to their interrogatories. @nobk4me - thank you - the request for a waiver from the obligation to answer until such time the Court has ruled on the motion has been incorporated. @Xcalibar - comment & questions: 1. I will file the MMDS and related requested dismissal based on Rule 10(D). 2. I will contemporaneously file a Motion to Withdraw Defendant's Discovery Request (stipulating the withdrawal is made pending Defendant's Answer to the Complaint) as recommended, however......................can you explain what is meant b
  8. is how I am planning to respond to Plaintiff's Interrogatories..... Any changes or other....please advise...thanks! --------------- Defendant Responses INTERROGATORY 1. State your full name. Answer: Name Here INTERROGATORY 2. State any other names which you have used or been known by. Answer: NONE INTERROGATORY 3. State your current residential address and telephone number. Answer: Residential Address Objection – Defendant has not refused or avoided service of this court. Plaintiff’s request for Defendant’s home residential address is immaterial to this
  9. @legaleagle....thanks for your input. Got on the MMDS...makes sense. Regarding responding to their interrogatories...i was specifically told by lawyers here in town...that I do not have to respond within the 28 days unless compelled to do so by the Judge...but u think its a bad idea from a perception point of view. you know about this specifically related to Ohio rules? Will research further. My interrogatories are actually useful to me - at least I believe they will be if we have to go further down the road. I want them to state some issues around the economics and also their line o
  10. Thanks great info here...also looking at florida...
  11. Thanks great info here..checking out homepath..
  12. in the mainstreams...Newcastle all the way...