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  1. I just received the plaintiff's response to my plea to the jurisdiction, and special exception I sent off courtesy of the help from Texasrocker. Each reply was in a separate envelope. My court date for this is October 29th so any helpful info will greatly be appreciated. I am just now trying to figure out what the next steps would be or how to properly object to (and get this stuff thrown out) this info they obviously are going to bring up as evidence. The only thing they have my info on is the affidavit from the expert "custodian of records" for Portfolio Recovery, Larry Whitaker. ** Objection hearsay, chain of custody, as Mr. Whitaker is not an expert to the financial records of Citibank...** But the bill of sale from Patricia Hall is very generic. Then behind that is a blank "Exhibit 1 Asset Schedule" it looks like they blanked everything out. Then the printout of all my info from an excel spreadsheet and down @ the bottom says " Data provided by Portfolio Recovery Associates, LLC from electronic records provided by Citibank, NA pursuant to the sale of accounts from Citibank to PRA" In the response, the mention Texas DOT v. Arzate, 159 s.w.3d 188,190( Rex. el paso 2004, no pet) I think it is supposed to be Tex not rex. and then Bland ISD v. Blue, 34 s.w.3d 547,554 (TEX. 2000) --------------------------------------------------------------------------------------- Since they separated the Plea to Jurisdiction and the special exceptions, I will do the same. And again any help will be appreciated.
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