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Motion for more time by the JDB? Can I ask for denial?

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JDB, says they need more time to find the information I requested (roggs, addmissions, and production of docts.) Atty. for them says they need more time to find information and have sent me notice of this motion set for next week. Should I, orally, ask the court to deny this motion based on the grounds of they filed an affidavit stateing I owe it, they filed this nearly 60 days ago and state in their complaint they aquirred (bought) this account in 2003. That's nearly 5 yrs ago and they should have had this by the time they filed this suit on me originally in Nov.!

I also have question about moving to strike their exhibit, which is a sworn affidavit from one of their officers, not he OC, that they bought it and I owe it. It includes, what they claim, I owe. Can I do this on the same day, and will it need to be written form? Do I have to submit it to the court and the plaintiff before court in written form? I have read my RCP and it's not clear to me.


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Something to this effect:

"Plaintiff has had plenty of time already to get the documentation in question, if it even exists. Plaintiff should have had this documentation before it filed its frivilous Summons and complaint.

Defendant respectfully insists current deadlines are sufficient."

Have a motion to dismiss ready. And an order the judge can just sign on the spot dismissing.

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