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  1. My wife and I bought a campground membership (a 1/5000th undivided interest) back in 2000 for $5,000 in north Georgia. We signed a warranty deed and a UDI agreement. We paid for the UDI in full, but never received the warranty deed. As we lived in Atlanta at the time we thought we would use it often. Turns out we did not. We moved away to another state not long after and have not been back to the area now in 14 years. We paid yearly maintenance dues and taxes until they went up sharply (they are now over $850 a year) and they came up with a "levy fee" of $2,000 for each member for them to reco
  2. Georgia Code section 24-9-902(11) reads in part: "A party intending to offer a record into evidence under this paragraph shall provide written notice of such intention to all adverse parties and shall make the record and declaration available for inspection sufficiently in advance of their offer into evidence to provide an adverse party with a fair opportunity to challenge such record and declaration;" The paragraph is referring to business records that are certified by affidavit in leiu of live testimony of the custodian of the record. My questions: How and when is this "written notice"
  3. I've been served in Magistrate Court of Cobb County by Midland Funding. My question is how do I file an Answer when there are no numbers to reference? I've searched this site and googled else where for a sample but am having trouble locating a sample that does not reference numbers. Additionally, how do I find out when hearings are being held in my court? I'd like to go sit in on a few of these cases but can't get anyone on the phone and obviosuly am using the wrong search terms to locate the times of hearings. 1. Who is the named plaintiff in the suit? Midland Funding LLC 2. What is the
  4. How I lost against Midland Funding in Georgia and then "won" ! Summary: Midland Funding (attorney: Hanna and Associates) sued for a credit card debt in State Court. Judge ruled in in favor of Midland Funding. We appealed to the GA Court of Appeals. Midland offered a settlement agreement and to vacate the original judgement in return for dropping the appeal. The appeal was dropped and the judgement was vacated. Attached are documents that we hope will be useful to the forum readers, especially from Georgia. 1. Transcript of the bench trial in State Court. If you have a trial in St
  5. I recently received a summons to superior court in Georgia for a credit card I know nothing about. The plaintiff is Cavalry SPV and the attorney is Hanna & Assoc. I answered the summons, and now I am drafting responses to the Request for Admission of Facts, Request for Production of Documents, and Interrogatories. I am listing the questions and my answers below -- I would sincerely appreciate any advice or critiques, as this process has a very steep learning curve. Thank you in advance. Request for Admission of Facts 1. You applied for, and received, a credit card account No.XXXX
  6. Hi everyone. I am preparing my appellant brief for the Georgia Court of Appeals in a case against Midland Funding. There were so many court and defense errors at the trial that I am 99% sure I will win the appeal. But I could use some extra eyes to review the brief since I have not done one before. It is due in two weeks. Has anyone on the forum created a brief for the Georgia Court of Appeals in the past that I could send this to privately to review? Thanks.
  7. I've read a whole lot of threads regarding the ANSWERING of a Junk Debt Buyers' AKA Plaintiff's Request for Admissions and Interrogatories. But where are some good suggestions for the Defendant's (aka me) Request for Admissions and Interrogatories? I am looking to send a pre-emptive strike against a JDB's Atty here in GA (they've filed suit against me despite repeated requests to validate debt and a previous attempt at filing suit against me (which was dismissed without prejudice) Ive already done the request for production of documents this week. I have NOT received the Request for Admissi
  8. This has been going on since April and they sent me a MSJ last week. I did some digging and came up with this. I am going to file a motion to dismiss too, not sure how to word it. I know this is LONG but please someone look over and help me make it LAWYERISH ....THANKS IN THE STATE COURT OF HOUSTON COUNTY STATE OF GEORGIA some company Assignee of First USA Bank, N.A. Plaintiff, vs. ME Defendant. DEFENDENTS RESPONSE TO PLAINTIFFS MOTION FOR SUMMARY JUDGEMENT COMES NOW, ME, Defendant and responds some company Motion For Summary Judgement as follows According to Plaintiffs letter t