LAClipper

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About LAClipper

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  1. I didn't realize that I typed that. Anyways yes it was a Dismissal without prejudice.
  2. Wells Fargo Dealer Services Repossesed my Car in Dec 2010 for missing 2 payments. I was sent a Notice of intent to sell property and in it it an option to Reinstate if I paid the remaining balance plus any fees added. So i Paid the amount owed in its totality and in a few days recovered my vehicle and later was sent the Pink Slip. Now this shows up on my Credit Report as a Repossession, even though I reinstated the contract. 1. What options do I have at this point to repair this account on my report? Account Name: WFDS/WDS ACCOUNT TYPE: Auto Loan Closed Experian shows as Paid was past due 120 days Equifax shows as At least 120 days or more than 4 payments past due/ Paid Account Zero Balance Transunion shows as Repossession / Closed
  3. UPDATE: So i sent the CCP 96 to them and never received anything. I attended court on 4/10/2014 and I am glad to say that the case has been dismissed !! The JDB Lawyer never spoke to me and only spoke to the Judge before any cases were called for motions. I waited 15 minutes as 6 cases were Default Judgements due to not contesting to inadequate defenses. When he called my case the Judge said thank you for coming in the Lawyer has entered into this court the dismissal without prejudice as of 4/09/2014, this case is dismissed. And just like that it was done. I want to thank all those that assisted and provided their knowledge and patience to help me. There is far too many to name but THANK YOU !!!
  4. Okay so the other party never responded to my Meet and confer Letter about Plaintiff's insufficient responses to Defendant's First Request For Production of Documents. I have been so busy and fallen behind on this case. Whats my next step. Do I sent the CCP 96 now?? What about the Meet and Confer Letter?? Court is soon on 4/10/2014.
  5. 1.I did use the form Disc- 015, and I will hold on to it till the day is closer to mailing it. Does it need to be CMRRR? 2.I found Seadragons 60 Day Checklist. It's in ASTmedic's Post, titled How I beat Midland in California. So much helpful info in that file. 3.For the Motion in Limine I will read up and get familiar with the process and draft it when I get the response to my CCP 96. Only evidence I have received so far has been the following: a) Verification from Chris Blanton on JDB responses to my request for Production of Documents. Verification from Chris Blanton on JDB responses to my request Form Interrogatories. c) Two Credit Card Statements. d) Bill of Sale from OC to JDB with no Account number or names on it. Signed by Patricia Hall e)Assignment from JDB to Collections Company. Signed by Morgan J Smith for JDB and Autumn Hopkins for Collections Company. Based on this what should I prepare more on, any suggestions?
  6. Okay so for now I will read up on Motions in Limine and I already have the CCP 96 drafted and ready to sent out when the time is near. So where is Seadragons 60 Day out Checklist at? I could not find it, any help in the right direction would be appreciated. Should I start Drafting the motion in limine, or wait till I receive their response first after I sent it to them?
  7. Hello Everyone, This case is about to go to trial in about 2 months and I have been soo busy. But anyways I have a question for you all, before I proceed. Unifund CCR Partners was the company Suing us and now on my Credit Report it doesn't show up at all. What happens now? How do I proceed?
  8. Just a small update, I failed to realize that their is a time frame for sending my meet and confer letter. What should I do now, should I still send it to them and hope they agree or what other steps can I take now?
  9. Updated Version for my Meet and Confer letter: I write to meet and confer about Plaintiff's insufficient responses to Defendant's First Request For Production of Documents. For your convenience, I set forth below each request, Plaintiff's response, and the reason a further response must be provided. Unless Plaintiff agrees in writing to supplement each response and grants defendant an extension of time to move to compel, Defendant will be forced to file a motion to compel further responses. Request No. 1: ALL DOCUMENTS relating to or constituting ANY signed Credit Card Application between Defendant and OC. Response to Request No. 1: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (West Pico Furniture Co. v. Superior Court(Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to Responding Party. (Panzalas v. Superior Court(1969)272 Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, responding party answers as follows: Document which Responding Party contends are not privileged and/or otherwise statutorily protected, and responsive will be produced as responding party gains possession, custody, or control of them. Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks Any signed Credit Card Application between Defendant and OC. That request is not vague. Nor is it ambiguous or overbroad. “Vague/Ambiguous” Valid objection only if the question is totally unintelligible. A party has a duty to answer if “the nature of the information sought is apparent.” Deyo v. Kilbourne (1978) 84 CA 3d 771, 783. “Overbroad” Valid only if the question calls for an undue burden such as “shotgun” request, like for interrogatories” as they are too general (i.e., “Please state the identity of each and every person who has knowledge of the relevant facts of the litigation.”) See CEB, California Civil Discovery Practice (4th ed. 2009) §7.85. “Information equally available to asking party”: This only applies if a party has to go get public records, Bunnell v. Sup. Ct. (1967) CA2d 720, 723-724 or interview independent witnesses Holguin v. Sup Ct. (1972) 22 CA3d 812, 821. “Burdensome and Oppressive": Responding Party has not shown that the intent of the defendant was to create an unreasonable burden, or that burden created does not weigh equally with what requesting party is trying to obtain from it. See Mead Reinsurance Co. v. Superior Court (1986) CA3d 313. These objections, without any explanation, are without merit. Furthermore, this request is directly relevant to the cause of action stated in Plaintiff’s complaint. Request No. 2: ALL DOCUMENTS relating to or constituting ANY assignment to Plaintiff of the alleged account referred to in the complaint. Response to Request No. 2: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to Responding Party. (West Pico Furniture Co. v. Superior Court(Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit "A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks Any Assignment to Plaintiff of the Alleged Account referred to in the complaint.That request is not vague. Nor is it ambiguous or overbroad. “Vague/Ambiguous” Valid objection only if the question is totally unintelligible. A party has a duty to answer if “the nature of the information sought is apparent.” Deyo v. Kilbourne (1978) 84 CA 3d 771, 783. “Overbroad” Valid only if the question calls for an undue burden such as “shotgun” request, like for interrogatories” as they are too general (i.e., “Please state the identity of each and every person who has knowledge of the relevant facts of the litigation.”) See CEB, California Civil Discovery Practice (4th ed. 2009) §7.85. “Burdensome and Oppressive": Responding Party has not shown that the intent of the defendant was to create an unreasonable burden, or that burden created does not weigh equally with what requesting party is trying to obtain from it. See Mead Reinsurance Co. v. Superior Court (1986) CA3d 313. These objections, without any explanation, are without merit. Exhibit "A" is a copy of a Statement for a CREDIT Card account. These documents in no way show any assignment of the account in question to the Plaintiff. Nowhere is there any reference to any account number or any assignment to the Plaintiff. The documents requested, if they exist, constitute agreements between plaintiff and the original creditor. There is no good faith basis for plaintiff to contend that responsive documents are protected by the attorney-client privilege, the work product doctrine, or constitute trade secrets. If plaintiff does not have a valid assignment of the account at issue in the complaint, it does not have standing to pursue its claims. Please produce all documents responsive to this request. Furthermore, Plaintiff has agreed to produce Exhibit “A” but does not state that such documents constitute all documents responsive to the request. Such a response does not comply with California Code of Civil Procedure § 2031.220. Pursuant to that section, “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” Request No. 3: ALL DOCUMENTS constituting statements of the alleged account number XXXX showing all payments and credits from inception until present. Response to Request No. 3: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (West Pico Furniture Co. v. Superior Court(Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party.(Panzalas v. Superior Court(1969) 272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d 45.) Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit "A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks a complete history of the account referred to in the complaint. That request is not vague. Nor is it ambiguous or overbroad. “Vague/Ambiguous” Valid objection only if the question is totally unintelligible. A party has a duty to answer if “the nature of the information sought is apparent.” Deyo v. Kilbourne (1978) 84 CA 3d 771, 783. “Overbroad” Valid only if the question calls for an undue burden such as “shotgun” request, like for interrogatories” as they are too general (i.e., “Please state the identity of each and every person who has knowledge of the relevant facts of the litigation.”) See CEB, California Civil Discovery Practice (4th ed. 2009) §7.85. “Information equally available to asking party”: This only applies if a party has to go get public records, Bunnell v. Sup. Ct. (1967) CA2d 720, 723-724 or interview independent witnesses Holguin v. Sup Ct. (1972) 22 CA3d 812, 821. “Burdensome and Oppressive": Responding Party has not shown that the intent of the defendant was to create an unreasonable burden, or that burden created does not weigh equally with what requesting party is trying to obtain from it. See Mead Reinsurance Co. v. Superior Court (1986) CA3d 313. These objections, without any explanation, are without merit. Finally, Plaintiff has agreed to produce Exhibit “A” but does not state that such documents constitute all documents responsive to the request. Such a response does not comply with California Code of Civil Procedure § 2031.220. Pursuant to that section, “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” Request No. 4: ALL DOCUMENTS relating to or constituting ANY Contract between defendant and OC. Response to Request No. 4: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (West Pico Furniture Co. v. Superior Court (Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party.(Panzalas v. Superior Court(1969) 272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit"A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks Any Contract between Defendant and OC. That request is not vague. Nor is it ambiguous or overbroad. “Vague/Ambiguous” Valid objection only if the question is totally unintelligible. A party has a duty to answer if “the nature of the information sought is apparent.” Deyo v. Kilbourne (1978) 84 CA 3d 771, 783. “Overbroad” Valid only if the question calls for an undue burden such as “shotgun” request, like for interrogatories” as they are too general (i.e., “Please state the identity of each and every person who has knowledge of the relevant facts of the litigation.”) See CEB, California Civil Discovery Practice (4th ed. 2009) §7.85. “Information equally available to asking party”: This only applies if a party has to go get public records, Bunnell v. Sup. Ct. (1967) CA2d 720, 723-724 or interview independent witnesses Holguin v. Sup Ct. (1972) 22 CA3d 812, 821. “Burdensome and Oppressive": Responding Party has not shown that the intent of the defendant was to create an unreasonable burden, or that burden created does not weigh equally with what requesting party is trying to obtain from it. See Mead Reinsurance Co. v. Superior Court (1986) CA3d 313. These objections, without any explanation, are without merit. Exhibit "A" is a copy of a Statement for a CREDIT CARD Card account. These documents in no way show any Contract of the account in question between defendant and OC Nowhere is there any reference to any Contract between defendant and OC The documents requested, if they exist, constitute a Contract between defendant and the original creditor. There is no good faith basis for plaintiff to contend that responsive documents are protected by the attorney-client privilege, the work product doctrine, or constitute trade secrets. If plaintiff does not have a valid Contract on the account at issue in the complaint, it does not have standing to pursue its claims. Please produce all documents responsive to this request. Furthermore, Plaintiff has agreed to produce Exhibit “A” but does not state that such documents constitute all documents responsive to the request. Such a response does not comply with California Code of Civil Procedure § 2031.220. Pursuant to that section, “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” Defendant may wish to serve follow-up discovery after receiving all documents in Plaintiff’s possession, custody, or control. Please confirm that you will serve a code-compliant, verified, supplemental response (and produce any further responsive documents) within 10 days from the date of this letter. If you need further time, please let me know and I will consider a brief extension of time with a corresponding extension of time to move to compel a further response. Otherwise, I will have no choice but to move the Court for an order requiring a further response.
  10. 1) Are you suggesting I include these within each Objection or is the meet and confer letter solid. 2) Also I was sent the Responses to my RFPOD on February 26 2013, but they sent me the Original Verification of the JDB on March 15 2013. I believe Unverified Responses have no time limit for Motion to Compel. But for Verified Answers I know the deadline for Motion to Compel is 45 +5 if Mailed. When do I start the Countdown for the deadline and do weekends count? What happens if i miss the deadline?
  11. So here is my Draft, Please Suggest any changes. I write to meet and confer about Plaintiff's insufficient responses to Defendant's First Request For Production of Documents. For your convenience, I set forth below each request, Plaintiff's response, and the reason a further response must be provided. Unless Plaintiff agrees in writing to supplement each response and grants defendant an extension of time to move to compel, Defendant will be forced to file a motion to compel further responses. Request No. 1: ALL DOCUMENTS relating to or constituting ANY signed Credit Card Application between Defendant and CITIBANK SOUTH DAKOTA NA.. Response to Request No. 1: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (West Pico Furniture Co. v. Superior Court(Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to Responding Party. (Panzalas v. Superior Court(1969)272 Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, responding party answers as follows: Document which Responding Party contends are not privileged and/or otherwise statutorily protected, and responsive will be produced as responding party gains possession, custody, or control of them. Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks Any signed Credit Card Application between Defendant and CITIBANK SOUTH DAKOTA NA. That request is not vague. Nor is it ambiguous or overbroad. These objections, without any explanation, are without merit. Furthermore, this request is directly relevant to the cause of action stated in Plaintiff’s complaint. Request No. 2: ALL DOCUMENTS relating to or constituting ANY assignment to Plaintiff of the alleged account referred to in the complaint. Response to Request No. 2: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to Responding Party. (West Pico Furniture Co. v. Superior Court(Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit "A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks Any Assignment to Plaintiff of the Alleged Account referred to in the complaint.That request is not vague. Nor is it ambiguous or overbroad. These objections, without any explanation, are without merit. Exhibit "A" is a copy of a Statement for a Citi Card account. These documents in no way show any assignment of the account in question to the Plaintiff. Nowhere is there any reference to any account number or any assignment to the Plaintiff. The documents requested, if they exist, constitute agreements between plaintiff and the original creditor. There is no good faith basis for plaintiff to contend that responsive documents are protected by the attorney-client privilege, the work product doctrine, or constitute trade secrets. If plaintiff does not have a valid assignment of the account at issue in the complaint, it does not have standing to pursue its claims. Please produce all documents responsive to this request. Furthermore, Plaintiff has agreed to produce Exhibit “A” but does not state that such documents constitute all documents responsive to the request. Such a response does not comply with California Code of Civil Procedure § 2031.220. Pursuant to that section, “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” Request No. 3: ALL DOCUMENTS constituting statements of the alleged account number 5500 showing all payments and credits from inception until present. Response to Request No. 3: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (West Pico Furniture Co. v. Superior Court(Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to an the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party.(Panzalas v. Superior Court(1969) 272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d 45.) Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit "A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks a complete history of the account referred to in the complaint. That request is not vague. Nor is it ambiguous or overbroad. These objections, without any explanation, are without merit. Finally, Plaintiff has agreed to produce Exhibit “A” but does not state that such documents constitute all documents responsive to the request. Such a response does not comply with California Code of Civil Procedure § 2031.220. Pursuant to that section, “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” Request No. 4: ALL DOCUMENTS relating to or constituting ANY Contract between defendant and CITIBANK SOUTH DAKOTA NA. Response to Request No. 4: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (West Pico Furniture Co. v. Superior Court (Pacific Finance Loans)(1961) 56 Cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party.(Panzalas v. Superior Court(1969) 272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit"A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. Reason Why Further Response Must Be Provided: This request seeks Any Contract between Defendant and CITIBANK SOUTH DAKOTA NA. That request is not vague. Nor is it ambiguous or overbroad. These objections, without any explanation, are without merit. Exhibit "A" is a copy of a Statement for a Citi Card account. These documents in no way show any Contract of the account in question between defendant and CITIBANK SOUTH DAKOTA NA. Nowhere is there any reference to any Contract between defendant and CITIBANK SOUTH DAKOTA NA. The documents requested, if they exist, constitute a Contract between defendant and the original creditor. There is no good faith basis for plaintiff to contend that responsive documents are protected by the attorney-client privilege, the work product doctrine, or constitute trade secrets. If plaintiff does not have a valid Contract on the account at issue in the complaint, it does not have standing to pursue its claims. Please produce all documents responsive to this request. Furthermore, Plaintiff has agreed to produce Exhibit “A” but does not state that such documents constitute all documents responsive to the request. Such a response does not comply with California Code of Civil Procedure § 2031.220. Pursuant to that section, “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” Defendant may wish to serve follow-up discovery after receiving all documents in Plaintiff’s possession, custody, or control. Please confirm that you will serve a code-compliant, verified, supplemental response (and produce any further responsive documents) within 10 days from the date of this letter. If you need further time, please let me know and I will consider a brief extension of time with a corresponding extension of time to move to compel a further response. Otherwise, I will have no choice but to move the Court for an order requiring a further response.
  12. So do I need to type two letters one for each or can they be combined? Also can you point me in the right direction to drafting the letter/s?
  13. I sent this Letter in January in regards to the BOP: Does it count as a meet and confer letter, or do I need to send them another for the production of Documents? This letter is to inform you that I consider the papers you served on XXXXXX, 2013, in response to my demand for a bill of particulars in the above action to be inadequate and defective because, 1. Your offices have failed to list each alleged service, its date, and its location for your Common Counts remedy to stand. 2. The failure to document that the debt was included in the prior assignment renders the "chain of assignment" fatally deficient. Accordingly, you have failed to establish its ownership of the subject debt. Specifically, based on this bill of particulars there is insufficient reliable information or evidence that this alleged debt was included in the purported prior assignment in your "chain of title" necessary to validate assignment of the debt from xxxxxx MANAGEMENT, LLC to xxxxxxx. As a proximate result I therefore demand that you supply further information as requested in this letter or I will place a terminating motion AND a CCP Section 128.7 or CCP 128(a) 1-8 Sanctions motion on calendar for this being frivolous action or employment of frivolous tactics. Please correct the bill by adding the necessary detail and resubmitting it to this office by xxxxxxxx I look forward to your cooperation in this matter. Sincerely,
  14. Update: April 30 2013 Well my case got transferred from LA Courthouse to Norwalk Courthouse on the 2nd of April 2013. I never received anything from the Lawyer regarding my Meet and Confer Letter, sent on January 2013. I did Finally Receive their responses to my RFPD and the FORM ROGGS. (A) Requests for Production of Documents 1. ALL DOCUMENTS relating to or constituting ANY signed Credit Application between defendant and CITIBANK SOUTH DAKOTA NA. Answer: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (west pico furniture co. v. superior court(pacific finance loans)(1961) 56 cal.2d 407.) This request is objected to an the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party. (panzala v. superior court(1969)272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, responding party answers as follows: Document which responding party contends are not privileged and/or otherwise statutorily protected, and responsive will be produced as responding party gains possession, custody, or control of them. Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. 2. ALL DOCUMENTS relating to or constituting ANY assignment to plaintiff of the alleged account referred to in the complaint. Answer: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (west pico furniture co. v. superior court(pacific finance loans)(1961) 56 cal.2d 407.) This request is objected to on the grounds that it is vague, ambiguous and unintelligible as drafted. Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit"A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. 3. ALL DOCUMENTS constituting statements of the alleged account number 5500 showing all payments and credits from inception until present. Answer: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (west pico furniture co. v. superior court(pacific finance loans)(1961) 56 cal.2d 407.) This request is objected to an the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party.(panzala v. superior court(1969)272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit"A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. 4. ALL DOCUMENTS relating to or constituting ANY Contract between defendant and CITIBANK SOUTH DAKOTA NA. Answer: This request is objected to on the grounds that it is overly broad, indefinite as to time, and without reasonable limitation in its scope, thereby resulting in annoyance, embarrassment, or oppression to responding party. (west pico furniture co. v. superior court(pacific finance loans)(1961) 56 cal.2d 407.) This request is objected to an the grounds that it is vague, ambiguous and unintelligible as drafted. Responding Party objects to this request on the grounds that the question calls for information which is available to all parties equally and therefore, oppressive and burdensome to responding party.(panzala v. superior court(1969)272Cal.App2D 499; Alpine v. Superior Court (1968) 259 Cal.App.2d45.) Subject to and without waiving the foregoing objections, Responding Party answers as follows; Documents which Responding Party contends are not privileged and/or otherwise statutorily protected, responsive, and its possession, custody, or control are attached hereto as Exhibit"A". Discovery is just beginning in this action and Responding Party reserves the right to amend this response in the future. And it also includes a Verification form from CHRIS BLANTON. Received a follow up Letter with CHRIS BLANTON’s so called Verification attached to it from the Lawyer.(A few Weeks Later) Let me know if I should also post up the ROGGS A little bit longer. So as of today: 1) No court date scheduled. 2) Case Management Hearing Date not set. How should I proceed?
  15. I requested the BOP and they did not send me specific documentation. I am precluding based on the Bill of Particulars not the Discovery, BOP is not Discovery, as I was told by other members. Feel a bit confused on how to proceed.