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I beat Wolpoff :) but I still have a couple of questions


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Well a couple of weeks ago I got a garnishment summons for an old judgement. Knowing I could not afford the $400+ coming out of my paycheck every two weeks I got a copy of the original judgement and don't you know that they served me incorrectly way back in 200 for a citibank CC. So I filed a motion to vacate due to improper service and yesterday the judge granted the motion and reset a new trial date. Wolpoff has to send me a Bill of Particulars and I have to file a Grounds for Defense.

My question is now how do I use the fact that the statute of limitations is way past up(3yrs in VA)? Any help on how I quote this in my Grouns of Defense or do I file a motion to dismiss?

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The statute may not be up. If the suit was timely filed in the first place, Virginia law might say that is good enough. Usually, when a motion to vacate a judgment is granted, the case is "reopened" (not a legal term) instead of dismissed and refiled. That makes a difference in terms of the statute of limitations. Check the statute on vacating judgments and see what it says.

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