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About Steel_Sunrise

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    I'm a stay at home mom, my daughter is 11 months old and I have another bun in the oven. <3
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    Flowers, scrap books

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  1. Yes, you hit the nail on the head. You already started with the Gen Denial so now its their turn to PROVE their case. Don't help them. "Objections/Denials" for their Interrogatories and Diligent searches with nothing to show should be used to respond to their Production of Documents demands.
  2. Seems like you just need to make sure you have some ammo to fight it if it is brought up. Prove it is hearsay by providing an example that was successful in another case. Or perhaps if the JDB places a claim on your credit report you can show that the only requisite is knowledge of your personal information for them to place any amount of alleged debt with the 3 large agencies monitoring credit.
  3. During my Meet and Confer/Discovery the Plaintiff did the following: Denied my request for BoP on the Breach of Contract THEN (after more M&C) Responded to my request with boiler plate 1. Contract 2. More account stated information 3. Some sort of generalized document that makes no reference to my account but "suggests" it is a proof of assignment from the OC. Essentially they denied, then admitted, it is acceptable... but actually failed to give me the break down / including dates & totals which the alleged debt was based upon for their breach of contract complaint which i had requ
  4. The Complaint does not allege a date when the account was opened. Only the vague date of the alleged breach of contract and another date reserving the right to pray for additional interest (2010 to 2011)
  5. O.C. stated in the complaint is HSBC BANK NEVADA, N.A. They state that (Within the past four years, on or about April 30, 2010, the Defendant(s) breached the agreement by failing to pay the O.C.
  6. Request 1 I applied for and received the credit statement in the plaintiff’s complaint from O.C. Request 2 I used the credit stated in the plaintiff’s complaint. Request 3 I understood that by using the credit, I agreed to the terms and conditions set forth in written agreement by and between me and O.C. Request 4 The credit terms include a provision that the prevailing party in a dispute is entitled to attorney’s fees. Request 5 The credit terms include a provision for calculating interest. Request 6 I received billing statements from O.C. / for the account stated in the plaintiff’s complain
  7. Plaintiff’s first set of request for inspection and production of documents CCP 2031 •Request 1 Any and all correspondence by and between you and HSBC BANK OF NEVADA, N.A. / with relation to the account at issue in the plaintiff’s complaint. Response: After a reasonable search, Defendant is unable to locate any such correspondence related to the account at issue but reserves the right to supplement this response should such information become available. •Request 2 Any and all documents that evidence payments made by you with relation to the account at issue in the plaintiff’s complaint. Respon
  8. I like those responses from BV80. I am preparing to answer a similar document and may use something to that effect in my letter.
  9. Will do. I am hoping to have something drafted by this weekend. I have limited access to word processing programs.
  10. I've been trying to learn a bit more about the laws / procedures in my county. Reading a lot of info but I know it's not all sticking. lol I have received an interrogatory / admissions from the Lawyers. I need to prepare the reply / my interrogatory and send them off soon.
  11. Just an Update: (This is from my Register of Actions) Hopefully the lawyers will continue with their cookie cutter tactics and make this easier for me.
  12. I see. I'll do a little digging in that direction when I get a free moment also.
  13. My server recently received the stamped original PoS(s) for my answer and I believe someone mentioned we should mail one to the Plaintiff since the first letter only had the stamped answer in it with an un-stamped PoS. This correct? I've been gathering some information about the "Discovery" phase. While doing so, I have been sitting on my response to their rejection of the Demand for BOP and focused my free time in learning a bit more about whats coming up. Should I send the follow up to the BoP I wrote about previously? In regards to the Request for Production; I made a few changes to these
  14. I read it over again this morning before I turned in the Answer. They are vague and seem to be trying to get me to admit indebtedness so I figured it is good to go. I had a person over 18 who is not a party to the suit mail a certified letter to the Plaintiff which included the Answer (stamped) plus a proof of service (not stamped). I'll mail out the other 3 proof of services to the court tomorrow with a postage paid self addressed envelope so they can stamp them and return them to me. Once I receive it I'll have my server send out a copy of the Proof of service (stamped) to the Plaintiff Than
  15. 1. Plaintiff is now and was at all times mentioned herein either a corporation, a partnership, a sole proprietor, or other legal entity in good standing, and is the rightful Plaintiff authorized to collect the debt which is the subject of this action. 2. Plaintiff is informed and believes, and on that basis alleges that at least one Defendant is an individual who resides in the State of California. 3. Plaintiff is ignorant of the true names and capacities of the Defendants sued herein as DOES 1 through 10 inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff wil