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3kids4bc's Achievements


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  1. Case going to trial soon in California, LA county Discover Bank now via Suttell response to CCP 96 only described witness as "Custodian of records of plaintiff" care of the law firm P.O. Box in WA. No CCP 98 Dec. - does anyone have any case law or legal authority to cite in a Motion in Limine to exclude this "witness" ? They never served or filed a CCP 98 so don't know if Target v Rocha will apply?
  2. This is the 1st time I have ever posted a "Thread" .... but just got trial date and need help now. Hope I am doing this right!! 1. Who is the named plaintiff in the suit? Cach LLC 2. What is the name of the law firm handling the suit? Mandarich Law Group LLP 3. How much are you being sued for? $11K 4. Who is the original creditor? (if not the Plaintiff) Bank of America 8. What was your correspondence (if any) with the people suing you before you think you were being sued? NONE 9. What state and county do you live in? CA - Los Angeles 10. When is the last time you paid on this account? Never not our account 11. What is the SOL on the debt? 4 yrs 12. What is the status of your case? Trial date set for 2/13 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) YES 14. Did you request debt validation before the suit was filed? No -didn't known about it 15. How long do you have to respond to the suit? Complaints are for 1. Breach of Contract and 2. Common Counts -Answer filed already Did you receive an interrogatory (questionnaire) regarding the lawsuit? Yes answered all their discovery already. 16. What evidence did they send with the summons? Copy of Assignment, Copy of charge off statement, copy of card member agreement NEED HELP on propounding discovery on them specifically RFA's and what are cut-off dates for Pre-trial prep subpoenas Motion for Summary Judgment etc. in LA Sup Ct Limited Cases???? Where would I look for those dates and deadlines???? Have not heard from Mandarich since we filed answer either.... nothing, just the standard discovery requests everyone has posted on here... They r really pissing me off by submitting statements to the court on the CMC statement that they are trying to settle with us, when we haven't heard word one from them, other than discovery. Thank you in advance for any help with this nightmare...
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