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Question on JDB Attorney Verified Complaint


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I received a complaint from a JDB Attorney who is suing me. The complaint was verified. I answered the complaint and also included a demand for bill of particulars. After two requests, I finally received one worthless statement and a bill for attorney fees. The bill of particulars was NOT verified as was the complaint. In my research today, I discovered that if the complaint is verified, the bill of particulars must be verified too. My question is: In my motion for further bill of particulars, do I include failure to verify the bill as one of my reasons that the bill is defective? Or does the judge take care of noticing that? Do you have any suggestions on what is appropriate for the motion for further bill? Any samples? Do I include a memorandum in support of the motion? Thanks all for your help!! BTW, I'm in California.

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