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Hey All, Just received discovery responses from CACH, LLC. wherein they objected to my request for the purchase agreement on the grounds that it was protected as a trade secret. CA Evidence Code 1060. Has anyone had any success compelling this document from a JDB? If so, can you point me to a template? P.S. This is my first time posting, so if I didn't follow any of the normal procedures, my apologies in advance.

Would like some suggestions (or more specifically a template) to assist in compiling a memorandum of points and authorities. Have already created the motion similar to Linda7's offered template. The absence of Oregon Case Law is a challenge so can possibly use 9th District. Original Creditor - Chase Bank Buyer #1 - Purchasers Advantage Colorado Buyer #2 - Professional Bureau of Collections of Maryland (Colorado Same address as Buyer #1) Yeah! I know! I realize this is not an account just a file of random numbers The Complaint is for both Account Stated and Breach of Contract. Have answered and provided Defendants Affidavit of Denial for Plaintiff's NEW account. Thanking you in advance for your assistance. HP Memorandum of Points and Authorities for Motion to Strike Affidavit "Plaintiff's Affidavit of Assignment of Rights" This Affidavit of Assignment of Rights ("Assignment") is made and entered into as of this ____ day of _____ 2012 by and between Purchasers Advantage, LLC, a Colorado limited liability company with a place of business at 5295 DTC Parkway, Greenwood Village, CO 80111 ("Assignor") and Professional Bureau of Collections ojf Maryland, Inc., a Maryland Corporation with a place of business at 5295 DTC Parkway, Greenwood Village, CO 80111 ("Assignee"), both of whom may be collectively referred to throughout this Assignment as "Parties," or individually as "Party." Whereas, Assignor has purchased a file of certain charge-off accounts, which consists of certain Wells Fargo accounts hereinafter referred to as the "Purchased Receivables" and Whereas Assignor has forwarded the Purchased Receivables to Assignee for collection activity; and Whereas Assignee has determined that certain of the Purchased Receivables are eligible for Legal Action and wishes to take such legal action as contemplated, by Section 6 of that. certain Collection Agreement ("Collection Agreement") made by and between the Parties on June 28th, 2011; and Whereas, Assignor wishes to grant formal written consent to Asignee to proceed with such legal action as Assignee deems necessary to secure collection on the account Now therefore, the Parties mutually agree to the following promises, the receipt and sufficiency of consideration for which is hereby acknowledged! I. Account. The following information and any corresponding account information which shall be attached to this Assignment shall collectively be known as the "Account." Account Holder: Huey Pilot Account Number. xxxxxxxxxxxxxx9999 Holders Last Known Address: 5200 Airport Road. Cirrus, OR 97000 2.Assignment Assignor hereby assigns all rights title and interest in the aforementioned Account to Assignee for the sole purpose of initiating legal action on and pursuing subsequent collection activity on the judgment of the Account. 3. Acceptance. Pursuant to the requirements of the Collection Agreement, Assignee hereby accepts the assignment of all right title and interest in the aforementioned Account to Assignee for the sole purpose of initiatingj^gal jdion on and pursuing subsequent collection activity on the judgment of the Account IN WITNESS WHEREOF the Parties have executed this Assignment on the date first written above. s/s_Buyer #1 Purchasers Advantage a Colorado Limited Liability Company s/s Buyer #2 Professional Bureau of Collections of Maryland, Inc. On this any day of Month 2012 before me undersigned, a Notary Public in and for the State of Colorado personally appeared JDB Name #1 and JDB name #2, to me personally known, who, being by me duly sworn, did say the within and foregoing instrument was signed on behalf of said Buyer by authority of its Board of Directors; and that the said person as such officer, acknowledged the execution of said instrument to be the voluntary act and deed of said Buyer Notary Stamp Notary Signature (Kind of Bogus - may be a challenge?) (Circle not Square) (Missing Notary Number) (absent expiration date)