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Motions to Strike

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I am planning to draft Motions to Strike the OC affidavit and the bill of sale. Should it be all in one Motion or two separate ones?

I am also filing a motion to dismiss tomorrow because of non-service. I'm not sure if I should file the other motions at the same time (in case it's not dismissed) or wait until after the motion to dismiss is heard and decided? The trial date is in January.

Anyone familiar with NY law?

I also want to request a credit card agreement...should I go ahead and send a letter to JDB's lawyer? So far I got an affidavit, a bill of sale, and a year worth of statements.

Edited by jg2933
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