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Judge ordered that I produce bank statements....now what?


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During a motions hearing last week, the Judge ordered that I produce bank statements for an 18 month period to the Plainitff, who is JDB #3 in the chain of title. They now will have my bank statements showing payments to the OC, the OC credit card statements, the OC credit card agreement, and two bills of sales (one of which I busted them for possible forgery...see my other post), and an Affidavit of Indebtedness.

I motioned to strike the bills of sales and affidavit as hearsay, and also pointed out the whole forgery thing. The Judge will not rule on my motions to strike until the day of trial, which is next week.

With these bank statements soon to be in their possession, what does everyone think I should do? If the Judge allows the bills of sale and affidavit into evidence and overrules my motion to strike them, then the dynamics of this case will obviously change. Are there any other strategies I'm missing?

If it's going to be a losing battle, I'd like to at least be prepared with a fight as to the amount they are claiming is due and knock off all of the ridiculous interest fees.

Help! The trial is next week.

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And he is taking advantage of his bias against pro se' litigants.

You need to hire a good consumer lawyer to knock this judge on his a$$!

I hope you demanded a jury trial.

If trial is next week, I would take 30 days to produce. Hopefully, your bank takes lots of time to research the documents.

Put a request in with your bank the day before the trial. Maybe just USPS mail a written request a day before trial.

At trial, you can truthfully say, "I requested the documents, the bank is researching my request."

You will then appear to be "cooperative". If trial proceeds, it will then hinge on the JDB having nothing for evidence.

Did you assert the "assignment" or "chain of custody" defense?

Even if bank statements cause you guilt, if they cannot complete chain of custody or ownership of claim, they have no standing to recover.

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Actually, I tried arguing with the Judge that the bank statements where not in my possession and that I couldn't even recall where I banked at the time. The Judge told me that if I didn't produce the bank statements by 5 p.m. TODAY, I could be thrown in jail for up to 180 days. He said something along the lines of "the Plaintiff is holding a gun to your head, so you better get those statements one way or the other".

No, I did not request a jury trial. I'm in the middle of nowhere, so hiring a good consumer lawyer is not even possible. The nearest one is 200 miles away and I doubt a good attorney would help me a week before trial. The Judge already denied Plaintiff's motion to continue. In fact, it looks like they will now appear by phone for the trial, which hopefully, will be to my advantage.

The Plaintiff has already changed their chain of title around from their original submissions, and in fact, I have two bills of sales supposedly executed by the same guy from the OC, but yet they both have VERY different and distinguishable signatures and say the debt was sold to two different entitites. Neither of these bills of sales are notarized, so I would assume they should be thrown out. But with the Judge's comments, attitude, etc., I'm a little worried. We are under simplified procedures and he will not rule on my motions to strike as hearsay until the day of trial. I've pretty much decided that if he allows these bogus bills of sales into evidence, I WILL appeal!

Anyway, back to the bank statements, I guess I need to go down the path of "so I paid money to the OC, but how is the Plaintiff proving that I owe THEM this money?". In my eyes the chain of title is not good, but if the Judge thinks it is, then what?

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That's outragous!

Just tell the judge, I don't have any such documents in my possession and you sent a written request to the bank I believe was my bank in that time frame. Give him a copy of the request.

If bad recordkeeping (not keeping your bank statements in you personal possession) on your part gets you thrown in jail, you need to bring up judicial ethics charges against this judge!

I'd highly reccomend, you get any lawyer on this, maybe even one not experienced in civil litigation.

I think its evident this judge is going to rack you up on this, just object to preserve your appeal, and appeal.

You need to get the case out of this guy's court.

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I take it this is a former MBNA account based on your previous post....

Since judge is going to rack you up....

Exercise the arbitration clause in the credit card contract. That will get it out of his court.

Serve notice to opposing lawyer overnight and give copy to judge. (Just a letter, "I hereby exercise the arbitration clause in the alleged agreement to settle our dispute in case #_____")

This, contractually waives the other sides right to litigate!!!!

Judge may ignore your notice to force arbitration, but it gives the case another SOLID basis to appeal.

You do have the cardholder agreement, right? (Hopefully an unsigned one was submitted to court.)

If its arbitrated, you just reset the case back to start in arbitration. Yes, arbitration is a screw of your rights, but not any worse than this hick judge.

At that point, in a technical sense, case is stopped cold in court. Which may help you on this production issue.

If judge orders arbitration, you just bought at least 6 months (probably more like 12 months) if you demand in person hearing and are as big of a pain as you were in court.

Arbitration means nothing until the award is attempted to be confirmed in court. Get a good attorney to oppose confirmation (This save lawyer fees).

Just another idea on getting out of this guy's court room. He may want you out of his courtroom too, and you give him this "opportunity" by doing this.

Your only other option is to move to substitute the judge. I think you have no chance to get that.

If arbitration is ordered, and judge orders you to intiate, file with JAMS. Its only $250 upfront filing and JDB has to pay EVERY OTHER ARBITRATION FEE under the JAMS "minimum standard of consumer fairness". Stay away from NAF or AAA.

This is best advice I have without looking at the documents. Remember, I am in no way purporting to be giving valid leagal advice. You need to take my advice as "dissident ramblings of a troublemaker".

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Wow....that's pretty potent stuff! I do see your point though. I don't want to chance the loss, but at the same time, I think I do have a fighting chance.

So, let's say I do exercise the arbitration clause, then I could end up in even worse shape in the end, right? I don't think too many consumers are successful in those situations. If the consensus here on the forum is that I should do it, then I will. Let's hear some input please.

I still am not sure what to make of the Judge. He did say that his best friend works at the same company that I do. He seemed totally on my side at the pre-trial conference. When I made a comment to him that the Plaintiff did not have a signed contract or any kind of signed purchase receipts, he said "oh, really?". At that time, the Plaintiff also asked for the infamous bank statements, to which I responded that I didn't have any longer. The attorney then made a snide comment about doing a subpoena to get them, to which the Judge kind of just ignored them and told me that if I didn't have them, to write a statement indicating such.

Fast forward six weeks later, Plaintiff files a motion to compel the bank statements (mind you they didn't even do a courtesy letter or anything...just filed the motion) and a motion for sanctions. They were trying to prevent me from being allowed ANY evidence as sanctions. I of course filed a response and showed that I sent the typed statement stating I did not have the bank statements. At the motions hearing, the Judge changed his tune and ordered that I produce them. He did cite some lengthy explanation as to the potential of the Plaintiff filing an appeal if he didn't allow them that evidence. Does that mean the bank statements will hang me? Maybe, maybe not. So is it worth getting a transcript of the pre-trial conference to see exactly what he said about the bank statements? Or is it a null point now since he's since ordered I produce them?

At any rate, I think they've totally screwed up their chain of title with the "revised" bill of sales and such. Nothing they have is authenticated. They did get a rep from the OC to throw together a notarized affidavit a couple weeks ago stating the money was owed, I paid payments, etc., but it has no contact information (no address or phone number), and could even potentially be a fradulent document, who knows. I did verify that the notary is valid. The Plaintiff has amended their disclosure statement to show a rep from the OC as one of their witnesses, although they show the witness is from a state other than where the affidavit was notarized. I presume that since the affiant is not listed as a witness, then the OC affidavit could possibly be striken as hearsay.

What about our state statute on assignment notification? Can I use this at trial?

4-9-406. Discharge of account debtor - notification of assignment - identification and proof of assignment - restrictions on assignment of accounts, chattel paper, payment intangibles, and promissory notes ineffective.

(a) Subject to subsections (B) to (i) of this section, an account debtor on an account, chattel paper, or a payment intangible may discharge its obligation by paying the assignor until, but not after, the account debtor receives a notification, authenticated by the assignor or the assignee, that the amount due or to become due has been assigned and that payment is to be made to the assignee. After receipt of the notification, the account debtor may discharge its obligation by paying the assignee and may not discharge the obligation by paying the assignor.

(B) Subject to subsection (h) of this section, notification is ineffective under subsection (a) of this section:

(1) If it does not reasonably identify the rights assigned;

I'm just looking for any and all possible defenses at this point. The time is ticking on the bank statement thing and I sure as heck don't want to risk being thrown in jail over it. That, and it would totally piss the Judge off and I'd have no chance at all in winning. Do I really have any legal grounds to not comply with the Court's order? Any thoughts are appreciated!

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I don’t know the whole story, but I also find it odd a judge being so unreasonable. This judge sounds very arbitrary and capricious....and not feeling well.

…..As if you have control over a bank’s accounting dept.

I would file a complaint with your state’s judicial conduct and review board. Judges don’t want oversight trolling around their Court looking for something.

Also, if you inform the judge upon returning to court you have filed a judicial complaint against him. He’ll likely go snake. By most canons he should recus himself.

Otherwise, how's the county meatloaf? :-)

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Back to the arbitration clause.....

If I did exercise the clause, how would this go down? I mean does the whole case basically start all over again with an arbitrator? Do you both submit evidence and state your claim? Does the Plaintiff submit their stupid little bills of sales and affidavits again, and if so, can they just submit what they want and leave out the forged one? I guess what I'm getting at is can I use everything that I currently have in my possession against them?

And just as an after thought, can the Plaintiff exercise the arbitration clause at this stage? Since the attorney cannot appear in person due to a scheduling conflict and the Judge denied their motion to continue, just curious if they may pull something like that.

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if you dont have the bank statements,

you could do a "sworn affidavit" that the requested documents are NOT in your control or possession. you have no copy's to give them,

request that the PLAINTIFF subpoena, your bank(s) for the documents they want, saying since they are "personal records" you need that subpoena for them to be released. ( if the accounts closed usually the records been purged) best they may have on a closed account that old is a statement ""check number 123 for $XXX posted date. ect,,account balance,,

doubtful they will have "photo copies" of each check, this takes up to much computer space for a old/closed account..

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Well without saying anything that could be used against me in case my posts are being monitored, I still think that even if I:

a.) obtained counsel immediately;

b.) he/she successfully filed for a continuance;

c.) I filed some sort of sworn denial about the statements by 5 p.m. today

The outcome will no doubt be the same: the Plaintiff would subpoena bank statements and have them in their possession.

Let's say that the one payment that the OC references in their affidavit is listed on a bank statement (which so happens to be the same bank as the issuing credit card), but the bank statement only shows (as the previous poster mentioned) a generic check number and an amount that possibly is somewhat higher due to the convenience fee charged. That really isn't incriminating in my eyes, but who knows what the Judge would think.

Let's also say that at the same time that I had two, or heck, even three different checking accounts. One of them could've been a business checking account that might have a payment or two referenced to the OC account. Would the "business use" of the card void any kind of credit card agreement, or cause any other issues to surface?

And as a final thought, if any of the bank statements show monthly transfers from other account numbers (that were a business or ex-spouse's account) then I'd bet that will open up a whole other can of worms. The Plaintiff will no doubt want to see statements for any other linked accounts at the time. Isn't there some sort of privacy law that protects against this stuff?

Well my time to submit the bank statements to the court is ticking away...I have four hours left before facing a possible visit to the county jail.

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And as a final thought, if any of the bank statements show monthly transfers from other account numbers (that were a business or ex-spouse's account) then I'd bet that will open up a whole other can of worms. The Plaintiff will no doubt want to see statements for any other linked accounts at the time. Isn't there some sort of privacy law that protects against this stuff?

one could object that its is "irrelevant" or burdonsome and costly to produce those "extra account information" banks charge per doc/ and or hourly for "research" make the Plaintiff pays if they really want them..as for a EX spouse they would have to join them in this to get access to thier records. as a 2ndor 3rd party.. this is really time comsuming and costly for a CA or . hey if you had Biz partners, does CA want add them too?

so what if it shows one or two payments? they have to show more than that to win against you, still wont prove you owe the CA money.or the amount they want..

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One party would have to file and equivalent summons and complaint...you get to answer...motions...blah blah.

Arbitration does suck, but will it suck worse than this judge?

Only you can decide.

I don't see the downside to exercising the arbitration clause if you are almost sure you are going to get railroaded, unfairly, with judgment or jail for contempt.

If judge refuses arbitration, there will be an appeal whether you waived other side's litigation rights BEFORE judgment. (making judgment void)

If judge grants arbitration, you can defend and if you lose arbitration, the award means nothing until confirmed. Get lawyer to oppose court confirmation of arbitration award.

In the meantime, a class action at an appealatte level could throw out credit card arbitration confirmation, like they did in my state. (if it hasn't been done in CO already).

Arbitration is essentially a private system of justice that attempts to mimic court, but is meant to be "informal". "Informal" meaning screwing uneducated consumers. Debt attorneys generally get pissed off when you exercise arbitration clause on them.

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Here's what I do to exercise the arbitration clause....

I send a letter to debt attorney first.

Dear scumbag;

"This is notice pursuant to the copy of the enclosed U.S. Bank cardholder agreement your firm REFUSED to send us as part of our FDCPA validation request. We are exercising Section #43, in relation to the summons and complaint filed by your “client” in the above case.

Clearly, once Section #43 is exercised by any party in any dispute, the other party waives all rights to litigation.

We expect immediate dismissal of case #________, in ________ County, CO, no more than 30 days from the date of this notice or we will petition the court for dismissal and sanctions against your client for willfully violating the very alleged agreement you are attempting to enforce.

If you decide to pursue any alleged dispute over this matter with JAMS, we fully expect your client to forward $250 to "JAMS”, per the alleged agreement, on our behalf, to fund a participatory arbitration hearing in our federal jurisdiction on our counter claims for your client’s willful violations of the FDCPA, and the Colorado Consumer Act."

This letter is tailored to U.S. Bank agreement, you need to tailor to MBNA. I can fax you a copy of MBNA agreement if you don't have. I only got a hard copy and it will not scan well.

Remember I exercise in my state because courts have stopped confirming credit card arbitration awards in my state. Arbitration exercise in my state not only waives banks right to litigate, but force them to a path that is a nullity. (dead end)

If you do this to get out of this guy's court, I can't stres enough to make JAMS the agreed on arbitration provider. They have an excellent "minimum standard of consumer fairness", you can object to NAF and AAA as an unfair waive of your rights. (More time dragging). And if you read the JAMS "minimum standard of consumer fairness" the MBNA arbitration clause is atrocious does not meet it, so you can raise that defense while in JAMS. Or use it to stop confirmation that JAMS did not follow their own rules.

Either way, this might make you enough of a deer tick to the debt lawyer to make him give up.

If it all goes to hell, and you eventually get a confirmed award, get a consumer lawyer to challenge credit card arbitration as procedurally and substantively unconscienable under state law using WI example. You could be the guy to liberate your state from credit card arbitration, the tide is starting to turn on this.

The point here is: you can immediately destroy their right to litigate. If you play your cards right, you screw them in arbitration as well. Arbitration can be very complicated for run of mill debt attorney used to only litigating, and they hate it.

You also have to remember, debt lawyer will not go to arbitration willingly. You may have to move to compel arbitration. judge may refuse, but you have good grounds to appeal just on this issue alone (ignoring all the other issues you got to appeal!) Tee it up for appeal.

I just don't see the downside doing this if the situation with this judge is as bad as you describe.

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Ok, I'm not in jail, but only because I did fax all of the bank statements to the Plaintiff's attorney by 5 p.m. (lol!). The order also said that I must file copies with the Court, but I missed the door closing by about 10 minutes, so I will do that this morning when they re-open. If you don't hear back from me, then that mean old Judge must've seen me at the clerk's window and had me arrested on the spot :)

trueq: Thanks all of the info. Actucally, my OC in this case is US Bank. The other post about MBNA is one that has disappeared, but I'm sure will re-surface as soon as this one is done.

The JDB's attorney did send me the cardholder agreement right after I filed my answer, so can they argue that I've had it for a couple of months now and should have seen the arbitration clause by now? I never did a FDCPA validation before they filed the summons....I had no clue about how all this worked, but I sure as heck do now. I would probably need to re-word that first paragraph of your letter.

I am still unsure as to the arbitration thing, but I have to make my mind up by today, as I'm leaving town for the weekend (work related) and trial is on Tuesday. So I'm desperatly trying to sort this all out!

First, am I the one and only person on this forum who has ever had a JDB's attorney ask to produce bank statements to link payments to the alleged debt? Surely SOMEBODY has gone through this? And if not, could this be a new tatic they are starting to use? If I'm the guinea pig on this, then so be it. If any of you attorneys on here had this happen to you today in court, what would you do (after all of your objections were struck down)? You can't just disobey the order, yet you don't want the Plaintiff to have this information either. What would you expect the outcome of the case to be at this point?

Second, am I holding too much value with the forged bills of sales? Basically, they sent one to me in their initial disclosure statement coming from OC to their sister company. Then suddenly, they got the OC to type up a quicky affidavit saying I made payments and that one was on xx/xx/05 (complete with the routing/account numbers), and stated I never disputed any charges, blah, blah. The OC affidavit then says they sold it to ABC Loan, on behalf of/by and through Plaintiff's sister company. So Plaintiff submits a NEW bill of sale coming from OC to ABC Loan, supposedly signed by same guy (VP of Retail Loss for OC) as the first bill of sale, but with two very different and distinguishable signatures (one is obviously a forgery). Then they had to cover that change of title, so they suddenly came up with a bill of sale from ABC Loan to sister company. None of these items are notarized (with exception of OC affidavit). How will the Judge view the above? If he strikes them from evidence, then all they have left is copies of bank statements, copies of credit card statements, the cardholder agreement, and the OC affidavit (which does contain hearsay, because affiant can't possibly know what ABC Loan did with the debt after they purchased it). Does anyone here see where the Judge could easily still rule that even with the lack of bills of sales in evidence, that I am still obligated to pay this money? Or is it pretty obvious that the Judge would have no choice but to rule in my favor since Plaintiff is lacking a good chain of title?

Basically I just need some solid opinions here. If I really don't have a fighting chance and a good defense, then I'm going with the arbitration. This is too much money to play with, as it's over $11k. If it were a couple grand, I'd be willing to risk playing it out.

Thanks everyone....I really appreciate all of the input!

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If not, read this,

http://www.debt-consolidation-credit-repair-service.com/forums/showthread.php?p=1013362#post1013362

If they don't show up with a witness, move to dismiss.

If they do have a witness, you first question on cross is "Do you work for US Bank?" If "no". Move to dismiss.

A witness for JDB cannot testify to the validity of your account being opened, and authorized by you, this is hearsay pure and simple. When they try to enter your bank statements....object.

Glad to hear I had the letter tailored to your case already.

I have 2 separate JDB suits over alleged U.S. Bank accounts, and the debt attorney continues to squel like a pig to this day on the arbitration exercise! (Granted arbitration in my state screws their rights) She refuses to arbitrate as the court ordered and continues to act like the litigation is "on", even though all matters in the case are "stayed" pending arbitration. (I'm suing her for exercising rights she knows do not exist!)

Despite this witness advice, the judge could still ring you up unfairly.

JUST MAKE DARN SURE YOU OBJECT UNTIL THE JUDGE TELLS YOU TO STOP!

If you don't object in the right spot, you may waive your right to appeal that issue.

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It still takes time to collect.

Even then, you can always ch.13 their a$$ and spread out their payments interest free for 5 years, while you keep all your assets.

OR

you can move to WI. file a Ch. 128 on them only, forcing them into a 36 month amortization program. No assets or other debt need to be in the plan.

128's only cost $22 to file.

I use a 128 on one judgment I have. It has an automatic stay like BK, but is marked "payment plan" on your credit report.

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Have they produced a witness list for trial?

If they don't show up with a witness, move to dismiss.

If they do have a witness, you first question on cross is "Do you work for US Bank?" If "no". Move to dismiss.

A witness for JDB cannot testify to the validity of your account being opened, and authorized by you, this is hearsay pure and simple. When they try to enter your bank statements....object.

Yes, they are listing as witnesses: 1) a rep from their own company (JDB is represented by in-house counsel), 2) a rep from their sister company (JDB #2 in chain of title), and 3) a rep for OC. Attorney has motioned for all witnesses to appear by phone, which Judge pretty much said he would grant during our last hearing when the attorney verbally brought it up. He went on this long explanation about how in the end he is looking out for my own good, as he wouldn't want me stuck with the added expense of flying these clowns into town.

So, I understand about witnesses #1 & #2 not being able to testify as to how the debt was created, etc., but the OC witness is what has me worried. With that said, what would you do in my position? Go for the arbitration, or go forward with the trial?

Thanks again trueq....your help is very much needed! I had no clue about the ch. 128 thing. Very interesting!

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But you can OBJECT to witnesses appearing by phone.

In my state, I had an attorney petition to appear by phone for a motion I filed. I objected. Judge made her come. She had to drive 5 hours each way for a 2 minute hearing.

The judge says its "for your own" good because he wants to dispose of the case.

Forcing the witnesses in person takes a long time to coordinate!

ALTHOUGH I HAVE NOT BEEN FACED WITH THE CIRCUMSTANCE YET, I WOULD NEVER, EVER SETTLE FOR CROSS EXAMING A WITNESS BY TELEPHONE! I want to pressure them in person on cross examination!

I would file a formal objection immediately. How do you know if all 3 of these witnesses are not working the boileroom at the JDB?

I'd also petition the court to allow you time to supoena these "witnesses" for a deposition in your jurisdiction, defense has to make them available.

But that is just me. I "stir the pot". I don't settle for the railroad job nonsense you are currently caught up in.

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Merrybucks: I did consider calling the guy with the two signatures as a witness, but I cannot locate him.

trueq: If I only had more time, I would be up for the fight, but as I said, I'm leaving town in a few hours and won't be back until very late Sunday night, which only gives me Monday and some of Tuesday to work on this whole mess.

Another consideration is that I'm right in the middle of buying a house. The lender knows about the pending litigation and said it was no big deal. However, if I lose, then I will no doubt end up with the judgment listed on my credit report, which could cause HUGE problems for me at the closing table. They could demand that it be paid off before closing. So, I'm really thinking that I should go for the arbitration thing. Worst case, the judge denies my request, I lose the trial, but then I have solid grounds for an appeal, which I would hire an attorney to handle. That will at least keep the judgment off of my credit report. Or am I missing something important here?

If it sounds like I'm on the right track, should I overnight the arbitration letter to the attorney and give them until say 5 p.m. on Monday to file for a dismissal? I know they will freak and fight it, and then that will only give me Tuesday morning to file my motion to dismiss, which of course the Judge will want to rule on it at the scheduled trial time.

Or am I better off filing a motion to continue and state that I want to deposition the Plaintiff's witnesses, blah, blah, and hope that it's granted? Remember, I diligently fought the Plaintiff's request to continue and the Judge denied their motion, so I will be in a tough spot to suddenly ask for a continuance myself.

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Merrybucks: I did consider calling the guy with the two signatures as a witness, but I cannot locate him.

trueq: If I only had more time, I would be up for the fight, but as I said, I'm leaving town in a few hours and won't be back until very late Sunday night, which only gives me Monday and some of Tuesday to work on this whole mess.

Another consideration is that I'm right in the middle of buying a house. The lender knows about the pending litigation and said it was no big deal. However, if I lose, then I will no doubt end up with the judgment listed on my credit report, which could cause HUGE problems for me at the closing table. They could demand that it be paid off before closing. So, I'm really thinking that I should go for the arbitration thing. Worst case, the judge denies my request, I lose the trial, but then I have solid grounds for an appeal, which I would hire an attorney to handle. That will at least keep the judgment off of my credit report. Or am I missing something important here?

If it sounds like I'm on the right track, should I overnight the arbitration letter to the attorney and give them until say 5 p.m. on Monday to file for a dismissal? I know they will freak and fight it, and then that will only give me Tuesday morning to file my motion to dismiss, which of course the Judge will want to rule on it at the scheduled trial time.

Or am I better off filing a motion to continue and state that I want to deposition the Plaintiff's witnesses, blah, blah, and hope that it's granted? Remember, I diligently fought the Plaintiff's request to continue and the Judge denied their motion, so I will be in a tough spot to suddenly ask for a continuance myself.

"I have two bills of sales supposedly executed by the same guy from the OC", you know he's supposed to work there, start at the OC..

if you want to do a depostion on the witness, the plaintiff should provide you with the contact information, just ask,. it would look Bad for the atty not co-oping with you,( hiding witnesses) on the affidavits signed by "witness" it should have had a mailing address or other contact info. start there, this should buy you some time, after all you need to set up a time for this right. better yet Depo all the witnesses..have your questions ready , check your court rules on how this must be done, usually you also need a "court reporter, transcriber" during questioning, A WARNING they may have atty there to object to questions, be ready to "reword" your questions, i would keep it simple, do you work for? what do you do there? do you mail out? how do you know if X is correct?

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