determined Posted February 14, 2005 Report Share Posted February 14, 2005 Plainiff has file a motion for summary judgment even though the judge ordered mandatory mediation because i file a motion to compel discovery. Plainiff answered motion for discovery with claiming trade secrets and still searchingfor application "contract". We sent a meet and confer this is what there response was.they sight Young v Climtro Southeast Distribution Corp 141 GA App 235 (1977) because they claim the answer was a general denial.They now have included a affidavit from the bank costodian who is a attorney They only include bank statements still in there motion The address on the bank statement are at the present address but the account originally opened at a rental property 3 years agoDoes anyone have any sugguestion on a denial or a case law we can sight to counter?They obviously do not have the contract all they have is the statementsAnd in the affidavid it does not state tha t he has personal knowledge that i charge the charges and without the contract how can the prove i charged the debt or requested the credit card in the first place.need to answer tommorrrow. Link to comment Share on other sites More sharing options...
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