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Motions to compel BOP vs. written discovery in Cal.

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There are many differences between a Bill of Particulars (BOP) and written discovery in California but one important one is often ignored: the motion to compel. Because this makes a real difference to debt collection defendants and they often don’t understand it until it is too late, I thought it would be useful to start this post.

Frequently, any discovery you serve on the plaintiff will be met by objections. To get adequate responses you will need to file a motion to compel. There are two major differences between a motion to compel a BOP and a motion to compel written discovery: deadlines and the separate statement.

A motion to compel written discovery must be filed within 45 days of service of responses to interrogatories (CCP 2030.300 3 c), demands for production of documents (CCP 2031.310 3 c), and requests for admissions (CCP 2033.290 2 c). The parties can agree to extend that time (which must be confirmed in a writing) but practically, the plaintiff won’t grant an extension unless your meet and confer efforts result in plaintiff’s agreement to supplement some of its responses. If you do not file a motion to compel by the deadline (or the extended deadline), you waive your right to do so.

In contrast, CCP section 454 contains no deadline for filing a motion. You can file one immediately, wait a few months, or even wait until trial and argue preclusion (depending upon your tolerance for risk).

In addition, a motion to compel written discovery must be accompanied by a declaration showing that you made a good faith effort to meet and confer with the plaintiff in an effort to resolve the issues informally. CCP section 454 imposes no similar requirement for a motion for a further response to a BOP. I strongly suggest that you write meet and confer letters before filing a motion to compel a further BOP, but there is no such requirement in CCP 454.

The biggest difference between the two motions, however, is the separate statement. Under California Rule of Court 3.1345, a motion to compel further responses to interrogatories, document requests and requests for admissions must be accompanied by a separate statement. Generally, this means a lot of typing. You have to set forth each request, the response, and a reason why a further response should be compelled. Here is the actual text of the rule:

A separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the separate statement by reference. The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following:

(1) The text of the request, interrogatory, question, or inspection demand;

(2) The text of each response, answer, or objection, and any further responses or answers;

(3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute;

(4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it;

(5) If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and

(6) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.

Bottom line: Filing any motion to compel is a lot of work. You will need to prepare a notice of motion, a memorandum of points and authorities and a declaration. But the separate statement is difficult to prepare, especially when you have a lot of responses. If you need information not available through a BOP, don’t propound Rogs, RFAs and RFPs asking for everything under the sun or you will be sorry when it comes time to prepare the separate statement and you have a deadline looming. If you need written discovery, consider propounding a small number of very specific RFPs first and maybe follow up with additional discovery afterwards. If you feel you need much more, consider staggering your requests so that your motions to compel are not all due on the same day.

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Sticky worthy information here...thanks calawyer!

Wish I had come upon this site before I sent out the ROGs and PODs before the BOPs...every situation is different, but faced with a lawsuit by a JDB, I'd recommend the following steps:

1. Most important..file your answer!

2. Send out BOP (I believe this only applies in CA and NY but other states have something similar).

3. Wait for the plaintiffs answer to BOP and prepare a meet and confer letter depending on the response (which most likely will be inadequate).

4. Begin to prepare the motion to compel and file it once the plaintiff (probably) ignores your meet and confer letter.

5. Depending on what information you get from the plaintiff in response to the BOP and motion to compel BOP, prepare the rest of your discovery requests.

etc, etc, etc

It's not a quick process, it will definitely be a long battle, but if you found this site, you are already on your way and the people here will help you every step!

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YOU ROCK Calawyer!!

I am fortunate to have found this site and you! I believe I have a fighting chance at this! THANK YOU!!!

And Scientific...good sound advice as well!!!

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Knocking it out of the park every single day CALawyer.

Who'dathunk it we have wonderful legal articles now. Good Job.

Edited by Seadragon
adding

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Sticky worthy information here...thanks calawyer!

Wish I had come upon this site before I sent out the ROGs and PODs before the BOPs...every situation is different, but faced with a lawsuit by a JDB, I'd recommend the following steps:

1. Most important..file your answer!

2. Send out BOP (I believe this only applies in CA and NY but other states have something similar).

3. Wait for the plaintiffs answer to BOP and prepare a meet and confer letter depending on the response (which most likely will be inadequate).

4. Begin to prepare the motion to compel and file it once the plaintiff (probably) ignores your meet and confer letter.

5. Depending on what information you get from the plaintiff in response to the BOP and motion to compel BOP, prepare the rest of your discovery requests.

etc, etc, etc

It's not a quick process, it will definitely be a long battle, but if you found this site, you are already on your way and the people here will help you every step!

Thank you everyone for all the great info and insight. And special thanks to calawyer for all the time spent helping us!

I'm new here and have a couple quick questions. Sorry if it sounds newbyish...

I have completed 1 and 2 above and just received my (insufficient) response back from Midland and now need to prepare meet and confer letter.

1. Do I make this letter on pleading paper?

2. Is there an example or template link where I can score an idea of what language to use for my discovery letter?

I'm actually enjoying this war:D

Edited by OhBoy!

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Thank you everyone for all the great info and insight. And special thanks to calawyer for all the time spent helping us!

I'm new here and have a couple quick questions. Sorry if it sounds newbyish...

I have completed 1 and 2 above and just received my (insufficient) response back from Midland and now need to prepare meet and confer letter.

1. Do I make this letter on pleading paper?

2. Is there an example or template link where I can score an idea of what language to use for my discovery letter?

I'm actually enjoying this war:D

The letter is just that, a letter. It does not go on pleading paper. Just do it like a business letter with your name and address at the top.

There are exemplars here. Search my posts for "meet and confer" and you should find them. If you can't, post again and I will find it for you.

Good luck.

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Hi calawyer, I have searched your (tons of) posts and could not find any examples of the meet and confer letter. Since the response from Midland was inefficient do I reply back in the meet and confer letter with all the interrogatories? I'm a bit confused between the discovery letter and the meet and confer letter.

Can anyone lead me in the right direction from this point? Thank you so much. :idea:

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Hi calawyer, I have searched your (tons of) posts and could not find any examples of the meet and confer letter. Since the response from Midland was inefficient do I reply back in the meet and confer letter with all the interrogatories? I'm a bit confused between the discovery letter and the meet and confer letter.

Can anyone lead me in the right direction from this point? Thank you so much. :idea:

This thread has a sample meet and confer letter that you can modify depending on your particular circumstances. Later on, there is also a motion to compel you can look at too.

http://www.creditinfocenter.com/forums/there-lawyer-house/307597-objection-bop.html

Good luck.

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Hi CA lawyer; Bohey here (again). This is a BOOK but with a few interesting uncovered twists...

As you suggested, I sent a response to Mandarich (CACH)'s meet and confer, citing 454 and the fact they failed to respond to my original request for BOP. I stated that I could not respond to their request of Aug 11 asking for corrections to the initial RFA, ROGS, POD since they had not provided proof that the alleged debt even belonged to me.

In their meet and confer letter, they stated they had not received a request from me for BOP, but I show they received service via CMCCR prior to the date of their M&C to me.

Then, under separate cover, (another letter), written on the same date of the first letter and received by me, (also on the same date of receipt of the meet and confer letter), they DID send a BOP. It included 1 statement showing just a final balance (no payments- no calculation of interest...) on 5/4-6/2/2010; an inadequate affadavit of sale and certification of debt signed by an officer of FIA (FIA?) M.K.Stephenson and notartized by Alicia Nicholoson of Gulford Co,NC.; A Bill of Sale and Assignment of Loan (boiler plate) signed by a VP of FIA (FIA?) on 7/20/2010; and a Summary Statement of Account Balance Purchased. This summary consisted of a sheet of paper with what looked like photocopied address labels laid out with the following information (respectively) on the labels: Account Balance Purchased <CACH,LLC>; Debtor name <not my full name on the summons/claim>; address label<address,OK>, Current creditor and address<CACH, LLC, and physical address>, statement date <8-12-2011>; CACH acct number<number they use>; original creditor name <MBNA America>; Original Creditor Account Number<5490354337937491>; Account Placement Date<07/21/2010>; Account balance on Placement Date <9631.49>

Then, THIS IS INTERESTING! The Affidavit mentions a NEW piece of information: <Account number 5409354999489500, formerly 5490354337937491"!!!!

I checked my other bill records and I found a letter from a Rogers Law Office for an FIA -BofA account with this "xxx9500 (" account number ... I think I paid it in 2009!

So now what do I do? Who and why is Mandarich suing me? Why was Rogers trying to sue me under the other number? They both have the same CACH account number... why are they trying to sue me under both account numbers with the same balance? Do they use TWO law firms (maybe they own?) to shore up the middle? Mandarich never mentioned the 9500 account number until sending this affadavit! How do I address this, or do I? Why was there another attorney, why are there two account numbers, both for CACH? I think I paid the 9500 account to Rogers, but, I sure don't want to go back and FIND all those records. I have not even LOOKED at my credit report; I can't imagine what nonsense is listed there! These guys are slimy! Who knows, Calawyer? Can I file a claim of improper collection practices under Rosenthal and get rid of this NOW!... I have not received a trial date - do I need to request a motion to compel... dismiss, request sanctions? I want damages!

Furthermore, when I first talked to Mandarich to tell them I didn't have an account, there were people in the background whooping,hollering,laughing and I told the "attorney" it sounded like a boiler room. The collector "attorney (yeah, right"), said, "I don't know what you mean". Just not professional sounding. ..

How can they say it is one number and then file an affidavit and add another account number (other than to cover their tracks?) saying it is a former account number they never mentioned iuntil now!? Doesn't that mean they have to acquire all the data proving that one number is the number they are now suing me for? Is there something I can do to STOP this from going forward based on the nonsensical, convoluted, alleged "FACTS".

What do I do, Calawyer?

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There are many differences between a Bill of Particulars (BOP) and written discovery in California but one important one is often ignored: the motion to compel. Because this makes a real difference to debt collection defendants and they often don’t understand it until it is too late, I thought it would be useful to start this post.

Frequently, any discovery you serve on the plaintiff will be met by objections. To get adequate responses you will need to file a motion to compel. There are two major differences between a motion to compel a BOP and a motion to compel written discovery: deadlines and the separate statement.

A motion to compel written discovery must be filed within 45 days of service of responses to interrogatories (CCP 2030.300 3 c), demands for production of documents (CCP 2031.310 3 c), and requests for admissions (CCP 2033.290 2 c). The parties can agree to extend that time (which must be confirmed in a writing) but practically, the plaintiff won’t grant an extension unless your meet and confer efforts result in plaintiff’s agreement to supplement some of its responses. If you do not file a motion to compel by the deadline (or the extended deadline), you waive your right to do so.

In contrast, CCP section 454 contains no deadline for filing a motion. You can file one immediately, wait a few months, or even wait until trial and argue preclusion (depending upon your tolerance for risk).

In addition, a motion to compel written discovery must be accompanied by a declaration showing that you made a good faith effort to meet and confer with the plaintiff in an effort to resolve the issues informally. CCP section 454 imposes no similar requirement for a motion for a further response to a BOP. I strongly suggest that you write meet and confer letters before filing a motion to compel a further BOP, but there is no such requirement in CCP 454.

The biggest difference between the two motions, however, is the separate statement. Under California Rule of Court 3.1345, a motion to compel further responses to interrogatories, document requests and requests for admissions must be accompanied by a separate statement. Generally, this means a lot of typing. You have to set forth each request, the response, and a reason why a further response should be compelled. Here is the actual text of the rule:

A separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the separate statement by reference. The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following:

(1) The text of the request, interrogatory, question, or inspection demand;

(2) The text of each response, answer, or objection, and any further responses or answers;

(3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute;

(4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it;

(5) If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and

(6) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.

Bottom line: Filing any motion to compel is a lot of work. You will need to prepare a notice of motion, a memorandum of points and authorities and a declaration. But the separate statement is difficult to prepare, especially when you have a lot of responses. If you need information not available through a BOP, don’t propound Rogs, RFAs and RFPs asking for everything under the sun or you will be sorry when it comes time to prepare the separate statement and you have a deadline looming. If you need written discovery, consider propounding a small number of very specific RFPs first and maybe follow up with additional discovery afterwards. If you feel you need much more, consider staggering your requests so that your motions to compel are not all due on the same day.

Sticky!!!!! This is great. Thanks Calawyer

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what did Calawyer or others recommend?

Hi CA lawyer; Bohey here (again). This is a BOOK but with a few interesting uncovered twists...

As you suggested, I sent a response to Mandarich (CACH)'s meet and confer, citing 454 and the fact they failed to respond to my original request for BOP. I stated that I could not respond to their request of Aug 11 asking for corrections to the initial RFA, ROGS, POD since they had not provided proof that the alleged debt even belonged to me.

In their meet and confer letter, they stated they had not received a request from me for BOP, but I show they received service via CMCCR prior to the date of their M&C to me.

Then, under separate cover, (another letter), written on the same date of the first letter and received by me, (also on the same date of receipt of the meet and confer letter), they DID send a BOP. It included 1 statement showing just a final balance (no payments- no calculation of interest...) on 5/4-6/2/2010; an inadequate affadavit of sale and certification of debt signed by an officer of FIA (FIA?) M.K.Stephenson and notartized by Alicia Nicholoson of Gulford Co,NC.; A Bill of Sale and Assignment of Loan (boiler plate) signed by a VP of FIA (FIA?) on 7/20/2010; and a Summary Statement of Account Balance Purchased. This summary consisted of a sheet of paper with what looked like photocopied address labels laid out with the following information (respectively) on the labels: Account Balance Purchased <CACH,LLC>; Debtor name <not my full name on the summons/claim>; address label<address,OK>, Current creditor and address<CACH, LLC, and physical address>, statement date <8-12-2011>; CACH acct number<number they use>; original creditor name <MBNA America>; Original Creditor Account Number<5490354337937491>; Account Placement Date<07/21/2010>; Account balance on Placement Date <9631.49>

Then, THIS IS INTERESTING! The Affidavit mentions a NEW piece of information: <Account number 5409354999489500, formerly 5490354337937491"!!!!

I checked my other bill records and I found a letter from a Rogers Law Office for an FIA -BofA account with this "xxx9500 (" account number ... I think I paid it in 2009!

So now what do I do? Who and why is Mandarich suing me? Why was Rogers trying to sue me under the other number? They both have the same CACH account number... why are they trying to sue me under both account numbers with the same balance? Do they use TWO law firms (maybe they own?) to shore up the middle? Mandarich never mentioned the 9500 account number until sending this affadavit! How do I address this, or do I? Why was there another attorney, why are there two account numbers, both for CACH? I think I paid the 9500 account to Rogers, but, I sure don't want to go back and FIND all those records. I have not even LOOKED at my credit report; I can't imagine what nonsense is listed there! These guys are slimy! Who knows, Calawyer? Can I file a claim of improper collection practices under Rosenthal and get rid of this NOW!... I have not received a trial date - do I need to request a motion to compel... dismiss, request sanctions? I want damages!

Furthermore, when I first talked to Mandarich to tell them I didn't have an account, there were people in the background whooping,hollering,laughing and I told the "attorney" it sounded like a boiler room. The collector "attorney (yeah, right"), said, "I don't know what you mean". Just not professional sounding. ..

How can they say it is one number and then file an affidavit and add another account number (other than to cover their tracks?) saying it is a former account number they never mentioned iuntil now!? Doesn't that mean they have to acquire all the data proving that one number is the number they are now suing me for? Is there something I can do to STOP this from going forward based on the nonsensical, convoluted, alleged "FACTS".

What do I do, Calawyer?

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Can someone explain the timeline regarding discovery? I know that the timeline is 30 days prior to the trial date but does this mean that discovery can not be requested 30 days prior to the trial date or that a response to an initial discovery has to be completed 30 days prior to the trial date?

**** I have found the answer to my question. This pdf includes all important deadline or cutoff times here in Calf. and provides examples.

http://www.uchastings.edu/faculty-administration/faculty/piomelli/class-website/docs/Discovery-in-Wage-Hour-Cases-f10.pdf

Edited by xavi72
found my answer

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There are many differences between a Bill of Particulars (BOP) and written discovery in California but one important one is often ignored: the motion to compel. Because this makes a real difference to debt collection defendants and they often don’t understand it until it is too late, I thought it would be useful to start this post.

Frequently, any discovery you serve on the plaintiff will be met by objections. To get adequate responses you will need to file a motion to compel. There are two major differences between a motion to compel a BOP and a motion to compel written discovery: deadlines and the separate statement.

A motion to compel written discovery must be filed within 45 days of service of responses to interrogatories (CCP 2030.300 3 c), demands for production of documents (CCP 2031.310 3 c), and requests for admissions (CCP 2033.290 2 c). The parties can agree to extend that time (which must be confirmed in a writing) but practically, the plaintiff won’t grant an extension unless your meet and confer efforts result in plaintiff’s agreement to supplement some of its responses. If you do not file a motion to compel by the deadline (or the extended deadline), you waive your right to do so.

In contrast, CCP section 454 contains no deadline for filing a motion. You can file one immediately, wait a few months, or even wait until trial and argue preclusion (depending upon your tolerance for risk).

In addition, a motion to compel written discovery must be accompanied by a declaration showing that you made a good faith effort to meet and confer with the plaintiff in an effort to resolve the issues informally. CCP section 454 imposes no similar requirement for a motion for a further response to a BOP. I strongly suggest that you write meet and confer letters before filing a motion to compel a further BOP, but there is no such requirement in CCP 454.

The biggest difference between the two motions, however, is the separate statement. Under California Rule of Court 3.1345, a motion to compel further responses to interrogatories, document requests and requests for admissions must be accompanied by a separate statement. Generally, this means a lot of typing. You have to set forth each request, the response, and a reason why a further response should be compelled. Here is the actual text of the rule:

A separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the separate statement by reference. The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following:

(1) The text of the request, interrogatory, question, or inspection demand;

(2) The text of each response, answer, or objection, and any further responses or answers;

(3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute;

(4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it;

(5) If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and

(6) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.

Bottom line: Filing any motion to compel is a lot of work. You will need to prepare a notice of motion, a memorandum of points and authorities and a declaration. But the separate statement is difficult to prepare, especially when you have a lot of responses. If you need information not available through a BOP, don’t propound Rogs, RFAs and RFPs asking for everything under the sun or you will be sorry when it comes time to prepare the separate statement and you have a deadline looming. If you need written discovery, consider propounding a small number of very specific RFPs first and maybe follow up with additional discovery afterwards. If you feel you need much more, consider staggering your requests so that your motions to compel are not all due on the same day.

Great! I'm still confused:? So I don't need a separate statement for a Motion to Confer an inadequate BOP? I have a Pre-Trial on April 16th, can I still file a MTC?

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I am courrently working on a law suit by CACH, LLC Trugh Mandarich law group, in California. I sent the discovery requests, and they perty much denided most of them! and this trend gives me alot of ideas. At this moment I am working on the Case Management Statement, and working on my Motion to Compel, the thing is that I never had a credit card with Bank of America, and they are claiming that I owe $14,200 to Flit Bank/ B of A.

calawyer! I love your postings, they make all the sense in the world, Me! I have never being in a situation like this in my entire live, I would appreciate any and all the help that you could give me. I am totally ignorant about this situations. If you could contact me? it would be Awesome. PS. My name is Juan. Just found out, that I need 20 or more postings, to be able to give you my email

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but first things first....

Don't use your real name.

Second start your own thread and answer these questions so everyone can help. http://www.creditinfocenter.com/forums/there-lawyer-house/242744-qs-answer-when-posting-forum-please-read.html

regards...

It is much better to start your own thread and here is why.

We have a lot of posters here from California. I try to help them all. When you start your own thread, all of the information is in one place. Whether you are being sued by an OC or a JDB. What stage of the case you are in. What discovery you have served and what response you received.

With PMs, that information is not available. Plus, when you post on your thread, some experiance posters may well answer the question for me--and save a bit of time.

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If you're going to be sending a 2nd M&C - give them a short window - like 5 days to reply. File your MTC by Halloween.

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Any help, please? Trial is January 17

If you have met and conferred and you don't have an adequate response, you can send one more letter or just file the motion. THere is no meet and confer requirement for a BOP. But Judges do like it.

Remember, if plaintiff says "this is all we have", then preclusion won't hurt the plaintiff at all. If it doesn't have any more documents, it can't be harmed by an order that says "you can't use them".

You should really post in your thread. That way we can look back and see what is going on in your case.

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I just read this and I'm starting to get confused again.

I have sent my BOP and I'm waiting for a response. I did write my demurrer

which is posted under Capital One Nelson Kennard Summons.

What is my next step. I don't even know if the demurrer is good. Seadragon thought it was ok, but what do I need to prepare for next. I'm getting super confused. The court said I was subserved which meant I had 40 days instead of 30. Is this true should I trust them. Should I go back and make sure?! HELP:confused:

I was served Oct 2. I still want to stick to the 30 day rule. I don't want to get screwed.

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I remember being subserved and so had 40 days to respond. I still filed my General Denial 30 days later, cuz I was nervous about it.

Actually, even if you file on the 41st day, you're not in default if the plaintiff hasn't requested a default yet.

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also file a motion to compel if they don't answer the BOP. what you are trying to do in this:

1. If they don't answer BOP push them with a Meet and confer letter about the requirement of 10 days and you will give them 2 days because you need the documentation to plead if they do not you will have to motion in exparte to compel production or preclude the giving of evidence and sanctions

2. The demurrer will have to be ruled on the court if it really doesn't state a cause of action will sustain the demurrer and the will have to serve a first amended complaint

3. the court could deny the demurrer and force you to answer in 10 days(don't worry we have help on that)

4. after answer, discovery happens which you want to stretch out and build on responses to your requests.

then prepping for trial.

I believe in you.

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Thanks for the outline of what to do next. Support and encourgement helps! My stress on this goes up and down. It has become very difficult to deal with. Just when I think I understand it I read some more and then realize I don't. If you need to loose weight this is it. I've lost 8lbs in 3 days. :cry:

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