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  1. I believe a way to disrupt the business records exception to the hearsay rule is to obtain the sale documents from The OC to the assignees. This will most likely hinge on the subpoenaing of that record from the OC. JDB's like to subpoena records from the OC so that they avoid there assignors charges for records. This will be a tough road because for the most part it involves out of state subpoenas. As a method to destroy affiants foundational claims it will help to refute the conclusory statements in affidavits declarations etcetera. I brought up this point here: http://www.creditinfo