pegasuscolt

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About pegasuscolt

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  1. Skippy, Thank you for taking the time to respond. I don't take what you said personally; I know this is my fault for not being on top of things so I appreciate any and all feedback and assistance I can get here. Thanks for your advice, but I'm not sure what you mean by a PM? Can you please clarify what that stands for?
  2. continued: 3. This responding party objects to all discovery requests to the extent that they request information protected by the attorney-client and/or attorney work product privileges, or by way of any other applicable privilege, and responses to any such discovery shall not be deemed a waiver thereof. 4. Without waiving any of these objections, this responding party will respond to the request for production in accordance with the applicable law and with this responding party's understanding of the fair meaning of the request for production. RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMEN
  3. Thank you both Skippy and rt for your response. Attached below is the Interrogatorries and RFP of docs that I originally sent them. Are you suggesting that I should send another one instead of a Meet and Confer letter or a BOP? According to my understanding of what I've read here, this is an account stated and because of that, BOP is not appropriate? The original cause of action is Common Counts. If that's the case, I'm not sure what the difference is between doing either a M&C letter or another set of RFPs if I am going to help the lawyers strengthen their case. I certainly don't want t
  4. Hello Everyone, It has been a few months since my last post and I must say, I'm a bit embarassed that so much time has elapsed. Unfortunately, I had to deal with some personal issues, but this is not to invite you to a pity party. I'm back in the game... Thankfully, the CMC back in October was for a non-appearance but I showed up anyways like everyone suggested and was sent home. Yesterday, we had a follow up CMC and after reading and practically memorizing ReadytoWininCA's case, since there are so many similarities (thank you for empowering me, by the way!), I was ready. The judge starte
  5. No, unfortunately I found this forum too late in the game and now I fear I am in way over my head over this...had I done a better job and had more time to research, I probably wouldn't be in the bind I am now. To briefly summarize, I was sent the Summons, filed my Answer (denials) with some Affirmative Defenses, and then filed a Request for Production of Documents and Interrogatories. The cause of action in the complaint was framed in the form of common counts, not breach of contract, where they said I had opened an account with Citi 4 years ago and have not repaid the debt. I honestly can't
  6. Thanks, ASTMedic. That's what I've gathered, but nevertheless this is pretty nerve racking as I've never gone into court before except for Jury Duty. I guess my best case is preparation, which this forum has done for me. Thanks again.
  7. Thank you both for your help. Hopefully the meeting won't be as bad as I anticipate it to be.
  8. Thank you, rte. So I still have time to reply even though the conference is scheduled for this Friday? Should I still show up as I planned?
  9. Hello All, I have a quick question regarding a Case Management Statement for my case in CA. I apology if this is brief and not as thorough to give all the details of the case or if someone has already discussed this, but unfortunately, I think I am on a time crunch. I received a Case Management Statement two weeks ago but wasn't sure if I had to do anything besides showing up to the Conference, which is scheduled for this Friday, 10/12. I have every intention of showing up. I was served back in June from Fulton Friedman & Gullace for Asset Acceptance, LLC, who purchased the debt from Citi