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Found 13 results

  1. I served PLAINTIFF witness with a subpoena and I try to file it at court. Today I received this notice. Plaintiff had served me with ccp 98 testimony in lieu for this witness. I served a subpoena for plsintiff witness and after being served i took it to the court to get it filed. The court returned the subpoena with the attached letter... I served a ccp 96 but they never responded. Will PLAINTIFF be able to use the Declaration in lieu of testimony of this witness during trial or any other evidence learned in discovery? I'm so nervous since I have court in 2 days😣😣😣😣 PLAINTIFF called today offering 50% off the debt as settlement, but I answer the only settlement I will accept is a DISMISSAL. They said they will talk to their client and get back to me... @sadinca
  2. Hi. This is my first post here. I've been searching high and low for help regarding a lawsuit filed against me by Portfolio Recovery Associates in Los Angeles County, and I'm at a loss as to how to proceed. I'm unable to afford an attorney, but my research has shown me that you can defend yourself on these cases, and actually have a decent shot of winning. After they initially served me, I figured out how to respond to their summons, and I did so with about as many affirmative defenses as I could find. Unfortunately, I missed the discovery phase and only started paying attention to the case again a couple of weeks ago when they served me with their witnesses "testament in lieu of live testimony." I know that I need to subpoena their witness, and I need to do it quick (trial is on the 6th of June), but I've never served a subpoena before, and I'd really like to do it right - could someone point me in the right direction?
  3. A friend of mine in Arizona recently divorced her husband. She just received a letter in the mail from JH Portfolio that is a Subpoena for Production and Copying of Documents. She has no income and no assets other than her car. Her husband is a veteran on disability. He is not paying her any spousal support. If they were ever served...most likely they were...he never told her anything about it. Any advice on what she can/should do at this point? Although she has lived in the US for 11 years or more, married to the same man, she never applied for US Citizenship. She would like to do so now, but is worried about how it will look to have cases filed against her so she would like to clear it up. She is currently residing with friends until she gets her life together. Any help would be appreciated! I looked up her case and found the following activity: 3/23/2016 SUBPOENA P 1 3/23/2016 FUND: FEES - MISC P 1 5/12/2015 DISCHARGE OF GARNISHMENT P 1 4/17/2015 CERTIFICATE OF SERVICE P 1 4/3/2015 WRIT OF GARNISHMENT FILED P 1 4/2/2015 FUND: CONST ETHIC COMM FUND P 1 4/2/2015 FUND: FEES - MISC P 1 2/13/2015 CERTIFICATE OF SERVICE P 1 2/4/2015 FUND: FEES - MISC P 1 2/4/2015 FUND: OVERPYMT FORFEITED P 1 1/30/2015 FUND: FEES - MISC P 1 1/30/2015 SUBPOENA 12/12/2014 CIVIL DEFAULT JDGMNT GRANTED 11/25/2014 MOTION FOR JUDGMENT P 1 9/9/2014 APPLICATION/ ENTRY OF DEFAULT P 1 8/5/2014 CERTIFICATE OF SERVICE 7/15/2014 CIVIL COMP FILED P 1 7/15/2014 FUND: PC JUDICIAL ENHANCEMENT P 1 7/15/2014 FUND: BASE FEES
  4. Hi, All. Does anyone have a reliable process server they can recommend (based on past personal experience) in the Greater San Diego area? I need to have a subpoena served on a JDB employee there. The job will require that they attempt personal service up to (3) times before leaving it with anyone else, sending me an Affidavit of Due Diligence (preferably in both electronic and hard copy form), and do it all in a very timely fashion. Any leads are very much appreciated, particularly if you can tell me a little bit about your experience with the company or individual being recommended. Thanks!
  5. I'm writing up my Objection to Plaintiff's Declaration in Lieu using @h8spleadingpaper's objection as a exemplar. I have a few questions and am hoping the California folks can help me out. For Argument A ("Failed to Comply With CCP Section 98") H8 states the declarant "does not say where the declaration was executed. He also does not give an address in California where he may personally be served." For my case, the declarant does give an address in La Jolla, CA where "this affiant is available for service of process ... during the 20 days immediately prior to trial. If service is of process cannot be effectuated at the aforementioned address, I authorize the Defendant to contact attorney XXX for purposes of effectuating proper service on my behalf." Also, the last line of the Declaration says "Executed on this day XXX, at San Diego, CA." So, I'm thinking I should either strike Argument A or rewrite it such that it only says the declarant was unreachable* by the process server. * The subpoena will be issued on Monday and I'm guessing the declarant probably won't be available, but will know for sure soon enough. I go to trial this week as well, so am getting the subpoena in just under the wire. I won't have 5 days to file the objections with the court, but do plan on overnighting a copy to PRA's lawyers so that they are aware I plan to fight back with gusto. Is this correct? -- PS: I'm terribly behind. I have two cases in motion - but they will be months apart. Unfortunately, I haven't been organized and missed my chance to do the preliminary stuff on suit #1. Nevertheless, I am inspired by those that have crammed a lot of learning into a short time and come out the other side. I'm determined not to let being behind stop me from trying. (Also, I worry that not fighting this will send the wrong message when it comes to suit #2. So, I'm in it to win it.) The one thing I have done is read, read, read this forum! I've seen that the members here will help people who are willing to do the work - and I am willing to work hard. Will probably have more questions over the next week, but I'll keep them all contained in this thread. Thanks in advance!
  6. Listen, I am not a lawyer and I am not an expert, by any means, but I've been reading this forum for over a year, and now that I have also had some experience in these matters, I feel compelled to make a few observations about (what seems to me to be) the general strategy that JDBs (junk debt buyers) use, at least in California. 1st – The JDBs depend upon the fact that most defendants are not going to answer the complaint filed against them, which allows the JDB to receive a default judgement, winning the case, and allowing the JDB to then proceed to garnishing the defendant's wages. 2nd – If the defendant does file an answer, the JDB's attorney will attempt to trick the defendant into admitting guilt or into making an error when responding to discovery requests, which the attorney will use to win their case. 3rd – JDB's attorney sends the defendant a CCP 98 (affidavit in lieu of live testimony) that will allow JDB to enter as evidence any documents attached, unless the defendant subpoenas the witness listed in the CCP 98 and files an objection to the CCP 98. 4th – The JDB's attorney, almost always, knowingly lies on the CCP 98 when they say that the witness will be available for service for the 20-days prior to the court date at an address within 150 miles of the court. It has been my experience, and it seems to me that in most cases filed in California, that a defendant has an excellent chance of getting their case dismissed if they simply follow the guidelines provided by ASTMedic in his topic: How I beat Midland in California. In addition, since ASTMedic's case, there have been two excellent cases that provide even more case law to use against the JDBs' strategy: Target v. Rocha and CACH v. Rodgers. Besides ASTMedic's guidelines, I also highly recommend the following two links that this forum lead me to, and which were particularly helpful to me. The first is a little old now, and was prior to Target v. Rocha and Cach v. Rogers, but contains actual filed court docs: http://www.plainsite...sandra-pacheco/ The second is the opinion from CACH v. Rodgers: http://www.courts.ca...ve/JAD14-11.PDF
  7. Hi, I filed my subpoena and its in the hands of the process server. Do I have to also answer the Plaintiffs Request for witness and evidence or is the subpoena enough. Or should I answer the plaintiffs request and attach the subppoena. The 20 day window for me to answer the plaintiffs request is on Feb 13, 2015. Well just heard from my process server and the affiant was PERSONALLY SERVED at the address listed on the CCP98. NOW WHAT?????
  8. I'm stressing! I have brain freeze! Not sure what to do now. I have to answer a CCP 96, don't know if I should subpoena a witness that works in Plaintiff's attorney's office - he submitted a CCP 98. HELP! Like I mentioned in another post, I'M in Ventura County, Calif, my case is assigned to Judge O'Neill, don't think he liked me much the 1st time I was in front of him. BV80 Xenophon
  9. Newbie here. I have been reading all of the information on this site for several weeks now, and believe I now am "up to speed" enough to post here for suggestions and/or advice. I also realize there is a basic list of questions I should repost (along with pertinent information) to get the ball rolling, but frankly I have so many issues to address, I will most likely need the assistance of the Moderator in determining which thread my posts/questions belong in. I do know that I must address the legal issues first (like the default judgments) but after starting the ball rolling with those, I have other "fish to fry" if I (we) are to better our credit situation. Long story short - like most folks, DH and I both suffered job losses (1 month apart actually) in late 2008/2009 due to lousy economy. Almost lost house, had car repossessed, and had to use credit cards to make COBRA payments and to pay basic living expenses. Able to regain employment, but at nowhere near previous income levels. Was advised by counsel (at the time) to stop paying the credit cards (which we did in 2009). Took in terminally ill in-laws (both have now passed) DH had major health problem....life happens. Discovered recently that DH has TWO default judgments against him, one discovered by accident (won't bore you with details) and one discovered when he was mailed a copy of a Subpoena Duces Tecum served upon the Custodian of Records for another banking institution who has NOTHING to do with the original creditor (Cap One). He filed a Motion to Quash the subpoena, and the SDT was promptly cancelled by counsel for Cap One. Presumably the original SDT was filed in order to attempt to gather info so they can collect on the Judgment, but when they saw what evidence we intended to introduce at the motion hearing, they very quickly cancelled the subpoena. Fast forward to now, and we discover a second default judgment in the Court record, and SOL issues pending for us to attempt a motion to vacate the judgment due to the fact he was never served with either Complaint. I have seen a few recent posts from others in California asking for input and advice with respect to motions to vacate judgments with no responses. Is that because it is impossible at this point? We are living very happily (and efficiently) without credit cards and have been for the last 5 yrs. - we don't really want or need another. However, we are really in need of a reliable (newer) car that we can drive to and from chemo appointments, without the risk of breakdown, and in order to even have a chance to buy a newer vehicle, we need to clean up some of this "mess." Also, the always lurking threat of a garnishment due to either of the Judgments is now in the back of our minds. Specifically, looking for input from those who have undertaken motions to vacate, preferably in California. TIA for any input or guidance you can provide.
  10. Who is the named plaintiff in the suit? JDB Hirishberg Acceptance Corp 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.)Hirshberg Acceptance Corp. The plaintiff is an attorney 3. How much are you being sued for?$1,152.42 includes court fees 4. Who is the original creditor? (if not the Plaintiff)American Express 5. How do you know you are being sued? (You were served, right?)Never received an original letter to validate. Just served and the server did not take my signature. 6. How were you served? (Mail, In person, Notice on door)In person at my home 7. Was the service legal as required by your state? Not sure, he gave me the letter and walked away. He did not ask for my signature. Process Service Requirements by State - Summons Complaint 8. What was your correspondence (if any) with the people suing you before you think you were being sued? I'd never heard from them prior to the complaint. If they sent a letter, I never received it. 9. What state and county do you live in? Michigan, Wayne 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations)March 2007 11. What is the SOL on the debt? To find out: 6 years in Michigan Statute of Limitations on Debts 12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Motion of Summary Judgement filed May 16, 2013. Pre-tail orders gave the May 27, 2013 for all motions, dispositive or oterwise, must be filed with court. 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?)The debt was never on my credit report. I did not have time to dispute except for the ANSWER. I don't think I did that right because immediately the date was set for pre-trail. 14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. I mention debt validation in my ANSWER. However, I don't feel I did it correctly. 15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? We've gone through all Discovery in which I didn't do correctly because I didn't give them a admit/deny. However, I asked them questions regarding my Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits 16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. They just gave me a complaint letter and the time I had to respond. No affidavit or anything. Later, I received a date for the pre-trail. I mentioned lack of information or knowledge and the judge immediately set a trial date. One mistake I made was when the Plaintiff called me into the hall and asked me if I ever had an account with American Express and I said "No." I told him I wanted to discuss this in the courtroom. That's when I mentioned the above statement. Now, JDB has issued a MSJ because I admitted to most of the Admissions questions regarding my residence and the fact that I did have an account with AE. My concern is that Hirishberg subpoenaed my bank account before they made contact with me about the debt. Before they contacted me, they had my bank account information, my driver's license, and statements from AE. My bank account showed where I had paid electronically on the account. I was never told that my bank account had been subpeonaed until a year later. They sent it to me at the end of March 2013. Then they said in the MSJ that they supeonaed my account 3/21/13 which is not true and if they did, they didn't inform me. Also, it would have been their second subpeona because the first was done in 2012 before they made contact with me. The Is that fraudulent? They even have a copy of my application from the bank with my personal info and signature for when I opened the account. It also states my social security number and my driver's license no. That's how they received most of my info. The Bill of Sale from the OC was not signed and none of the other Bill of sales had affidavits. During Discovery they did not submit a signed contract by me, no contract with Hirshberg and OC. I asked for the Subpoena order, they stated alread enclosed, but it was the one from 2012. I asked for the Bill of Sale and Assignment of Account in question, issued to the Plaintiff by OC just to see if they needed to make a correction because the OC signed to someone else but without signatures or affidavit (at least it wasn't included with the copy of the Bill of Sales sent to me). This is where I am. I have until May 22, 2013 or May 24, 2013 to finish this. Please help me and thank you all for taking the time to hear my plead.
  11. Who is the named plaintiff in the suit? JDB 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.)Hirshberg Acceptance Corp 3. How much are you being sued for?$152.42 includes court fees 4. Who is the original creditor? (if not the Plaintiff)American Express 5. How do you know you are being sued? (You were served, right?)Never received an original letter to validate. Just served and the server did not take my signature. 6. How were you served? (Mail, In person, Notice on door)In person at my home 7. Was the service legal as required by your state? Not sure, he gave me the letter and walked away. He did not ask for my signature. Process Service Requirements by State - Summons Complaint 8. What was your correspondence (if any) with the people suing you before you think you were being sued? I'd never heard from them prior to the complaint. If they sent a letter, I never received it. 9. What state and county do you live in? Michigan, Wayne 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations)March 2007 11. What is the SOL on the debt? To find out: 6 years in Michigan Statute of Limitations on Debts 12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Motion of Summary Judgement filed May 16, 2013. Pre-tail orders gave the May 27, 2013 for all motions, dispositive or oterwise, must be filed with court. 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?)The debt was never on my credit report. I did not have time to dispute except for the ANSWER. I don't think I did that right because immediately the date was set for pre-trail. 14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. I mention debt validation in my ANSWER. However, I don't feel I did it correctly. 15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? We've gone through all Discovery in which I didn't do correctly because I didn't give them a admit/deny. However, I asked them questions regarding my Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits 16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. They just gave me a complaint letter and the time I had to respond. No affidavit or anything. Later, I received a date for the pre-trail. I mentioned lack of information or knowledge and the judge immediately set a trial date. One mistake I made was when the Plaintiff called me into the hall and asked me if I ever had an account with American Express and I said "No." I told him I wanted to discuss this in the courtroom. That's when I mentioned the above statement. Now, JDB has issued a MSJ because I admitted to most of the Admissions questions regarding my residence and the fact that I did have an account with AE. My concern is that Hirishberg subpoenaed my bank account before they made contact with me about the debt. Before they contacted me, they had my bank account information, my driver's license, and statements from AE. My bank account showed where I had paid electronically on the account. I was never told that my bank account had been subpeonaed until a year later. They sent it to me at the end of March 2013. Then they said in the MSJ that they supeonaed my account 3/21/13 which is not true and if they did, they didn't inform me. Also, it would have been their second subpeona because the first was done in 2012 before they made contact with me. The Is that fraudulent? They even have a copy of my application from the bank with my personal info and signature for when I opened the account. It also states my social security number and my driver's license no. That's how they received most of my info. The Bill of Sale from the OC was not signed and none of the other Bill of sales had affidavits. During Discovery they did not submit a signed contract by me, no contract with Hirshberg and OC. I asked for the Subpoena order, they stated alread enclosed, but it was the one from 2012. I asked for the Bill of Sale and Assignment of Account in question, issued to the Plaintiff by OC just to see if they needed to make a correction because the OC signed to someone else but without signatures or affidavit (at least it wasn't included with the copy of the Bill of Sales sent to me). This is where I am. I have until May 22, 2013 or May 24, 2013 to finish this. Please help me and thank you all for taking the time to hear my plead.
  12. I need a subpoena served in Woodland Hills. However, I have been unemployed for 4 years and live on food stamps in a room provided by my father. I am 53 years old and am one of the millions who lost it all in the Great Recession and have yet to recover. I cannot afford a process server. Is there anyone who can help out? I have a separate thread i started regarding my case called "Going to Trial in California" if you want to know more about the case.
  13. 1. Who is the named plaintiff in the suit? 2. What is the name of the law firm handling the suit? 3. How much are you being sued for? X,XXX.XX plus 24% attorney fees a total of $XX,XXX.XX a total of $16,000 4. Who is the original creditor? (if not the Plaintiff) Chase OC, sold to JDB, and Transfer to 2JDB Inc. 5. How do you know you are being sued? not properly served. 6. How were you served? drop sumons andcomplain on the mailbox no envelope or stamp. Papers on mailbox, no envelope or stamp. 7. Was the service legal as required by your state? No. the best reason to vacate a judgment would be improper service CA 1. In lieu of personal delivery of a copy of the summons and of the complaint to the person to be served as specified in Section 416.10, 416.20, 416. 30, 416.40, or 416.50, a summons may be served by leaving a copy of the summons and of the complaint during usual office hours in his or her office with the person who is apparently in charge thereof, and by thereafter mailing a copy of the summons and of the complaint (by first-class mail, postage prepaid) to the person to be served at the place where a copy of the summons and of the complaint were left. Service of a summons in this manner is deemed complete on the 10th day after such mailing. 2. If a copy of the summons and complaint cannot with reasonable diligence be personally delivered to the person to be served as specified in Section 416.60, 416.70, 416.80, or 416.90, a summons may be served by leaving a copy of the summons and of the complaint at such person's dwelling house, usual place of abode, usual place of business, or usual mailing address other than a United States Postal Service post office box, in the presence of a competent member of the household or a person apparently in charge of his or her office, place of business, or usual mailing address other than a United States Postal Service post office box, at least 18 years of age, who shall be informed of the contents thereof, and by thereafter mailing a copy of the summons and of the complaint (by first-class mail, postage prepaid) to the person to be served at the place where a copy of the summons and of the complaint were left. Service of a summons in this manner is deemed complete on the 10th day after the mailing. (Amended by Stats. 1989, Ch. 1416, Sec. 15.) . Process Service Requirements by State - Summons Complaint 8. What was your correspondence (if any) with the people suing you before you think you were being sued? None 9. What state and county do you live in? California 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) there copy of electronic statements says , 09 11. What is the SOL on the debt? To find out: 4 years Open-ended Accounts 337a Statute of Limitations on Debts 12. What is the status of your case? Pending Suit serve. Motions filed? YES 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No 14. Did you request debt validation before the suit was filed? No 15. How long do you have to respond to the suit? Respond with General Denied Did you receive an interrogatory (questionnaire) regarding the lawsuit? YES Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits 16. What evidence did they send with the summons? Summons, Civil Case Cover Sheet, Complaint – Contract, Cause of Action – Common Counts, Cause of Action – Breach of Contract, Declaration Pursuant to CCP395 ( Venue for Personal Family or Household Obligations, Notice of Case Assigment, Alternative DR Information. 17. Read this article: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits ==================================================== Status Right Now: Complaint Demanding Less than $10,000 filed by Plantiff.\nRefers to: Defendant Civil Case Cover Sheet filed by Plantiff.\nRefers to: Defendant Original Summons filed by Plantiff.\nRefers to: Defendant Summons issued. Case assigned to Department Case initiation form printed. Certificate of Service filed by Plaintiff. Proof of Service of 30-day Summons & Complaint - Personal filed by Plaintiff.\nRefers to: Defendant Case reassigned from C-XX to Judge effective 0X/XX/XXXX Motion to Quash (Civil) scheduled for 0X/XX/XXXX at XX:00:00 AM at Central in X-XX Request to Waive Court Fees filed by Defendant Motion to Quash Service of Summons filed by Defendant. Proof of Service submitted by Defendant rejected on XX/XX/20XX. Notice of Hearing About Court Fees filed by Defendant. Fee Waiver Hearing (Civil) scheduled for 0X/0X/20XX at 0X:X0:00 PM at Central in C-XX. Notice of Hearing SD generated. Opposition to Noticed Motion and Supporting Declarations filed by Plaintff. Declaration - Other filed by Defendant. Tentative Ruling for Motion to Quash (Civil) published. Proof of Service filed by Defendant. Matter taken under submission. Minutes finalized for Motion to Quash (Civil) heard 0X/XX/20XX XX:00:00 AM. Minutes finalized for Fee Waiver Hearing (Civil) heard 0/0/20XX Order on Court Fee Waiver After Hearing filed by Defendant Matter decided. Miscellaneous Minute Order Finalized. Clerk's Certificate of Service By Mail (Minutes Only) SD generated. ** DEFAULT COURT JUDGMENT RECEIVED ** General Denial filed by Defendant Proof of Service by Mail (Proof of service Denial filed by defendant) filed by Defendant Civil Case Management Conference scheduled The Civil Case Management Conference was rescheduled Civil Case Management Conference scheduled . Case Management Statement filed by Plaintiff. Case Management Statement filed by Defendant Due to case reassignment, any and all dates currently set in this case have been vacated. Case reassigned from Old Judge to New Judge Civil Case Management Conference scheduled . Discovery Hearing scheduled for 0X/XX/20XX Motion to Deem Facts Admitted filed by Plaintiff. Judgment by Default by Court (DEFAULT JUDGMENT PACKET) submitted by Plaintiff rejected on XX/XX/20XX.\nRefers to: Defendant Case Management Statement filed by Plaintiff. Civil Court Trial scheduled for 0X/XX/20XX at 0X:00PM before Judge Minutes finalized for Civil Case Management Conference heard 0X/0X/20XX X0:00:00 AM. Notice of Hearing SD generated. Opposition - Other (MOTION FOR FACTS AND DOCUMENTS DEEMED ADMITTED) filed by Defendant. Case Management Statement filed by Defendant. Notice - Other (of trial) filed by Plaintiff. Notice - Other (NOTICE OF INTENT TO CALL AS WITNESS) filed by Plaintiff. Notice - Other (NOTICE TO COMPEL ATTENDANCE BEFORE COURT AND BRINGING OF BOOKS, DOCUMENTS OR OTHER THINGS) filed by Plaintiff. Declaration - Other (OF CUSTODIAN OF RECORDS PURSUANT TO CCP SECTION 98) filed by Plaintiff. Declaration - Other (OF ACCRUED INTEREST PURSUANT TO CC 3287(a)) filed by Plaintiff. Declaration - Other (IN SUPPORT OF PLAINTIFF'S EXEMPTION FROM USURY LIMITATIONS) filed by Plaintiff. Declaration - Other (DECLARATION FOR COSTS) filed by Plaintiff. Declaration - Other (IN SUPPORT OF ATTORNEY FEES) filed by Plaintiff. Declaration - Other (OF : ATTORNEY UNAVAILABILITY) filed by Plaintiff. Memorandum of Costs (Summary) filed by Plaintiff. Proof of Service by Mail filed by Plaintiff. I already Filed a 2nd BOP, meet and confer,Disc-015, sub-001. Plaintiff did not send me c96 before the 45 of trial 4-15 and i send my on 3-25 the trial date is 4-19. i am still waiting for the response of BOP, subpoena POS. need help in the next step; how to respond to their disc-015 still pending 20-days to respond and all the statements they send me, plus what is that i need to request from them? 1. NOTICE TO INTENT TO CALL AS WITNESS 2. NOTICE TO COMPEL ATTENDANCE CCP 1987( 3. NOTICE OF INTENT TO PRESENT DECLARATION OF CUSTODIAN OF RECORDS a) DECLARATION OF ACCRUED INTEREST DECLARATION IN SUPPORT OF ATTORNEY FEES AS EVIDENCE c) DECLARATION OF CUSTODIAN OF RECORDS CCP98 d) DECLARATION OF ACCRUED INTERES CC3287 (a) e) DECLARATION OF SUPPORT OF ATTORNEY FEES i) DECLARATION OF Brighton Husing-Kline ATTORNEY UNAVAILABILITY MEMORANDUM OF COSTS (SUMMARY) AND (WORKSHEET)