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  1. Hello everyone let me start by giving much thanks to all the contributing members on the Forums here. I have been a reader for a very long time about 10 years now, never been a poster but was able to use info found on here to help a lot friends get through their cases, some have won some have lost. Now that I am need of some assistance I really hope that some of you are able to help me. I just have a few basic questions. I found ASTmedics thread and really found that his strategy is the most easiest to follow so would like to employ the same. I started out initially preparing my Answer, BOP, and General Denial while I could find a lot of information on the Answer and have been able to locate standard format and wording for a BOP I am unable to find any thing for the General Denial that can be filed in CA in reply to a Civil Case. After further reading found that a BOP is not applicable to an "Account Stated" action which mine is. So guess I will be tossing the BOP I had prep'd for filling. This leaves me with the "Answer" of which I'm pretty competent is adequate although after reading the threads from Coltfan, ASTmedic, CaLawyer, Seadragon and others about the flaws of the various arguements they have seen presented and the outcomes I will be going back to the drawing board and changing my existing Answer especially with respect to "Lack of Privity" etc...because it was one of my many Affirmative Defenses. With that being said I like that a simple General Denial to get the ball rollin gives the moving party little info to use against you later on down the line. Which brings me to my post/request for help. 1. Is filling the General Denial alone enough? Or is including the Answer with the filling a good strategy to employ? Or later on? 2. Is the General Denial treated the same as an Answer by the courts, whereby it prevents moving party from filling for Default? 3. Can anyone point me in the direction or provide me with some sample Templates or Redacted fillings of a General Denial that can give me some guidance. Especially if I want to lay the ground work on having the suit eventually tossed on Hearsay etc... 4. Once either the Answer or General Denial or both are filed what is the standard time frame for me to send them a RPD? 30 days later, 30 days prior to trial? After I get their ROG's etc...? I want to be ahead of the game and beat them when it comes to this. Anyway any info that can be gleaned from anyone out there will help me tremendously because I intend to file my docs on Monday.
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