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Interrogatories and Request to Produce to be sent to Midland Funding Atty


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Does anyone know where I can find a sample of filing Interrogatories and Request to produce to be sent to Midland Funding. I had an attorney that filed an answer and affirmative defenses back in September 2009. Atty for Midland filed a motion for summary judgment but then filed a motion to withdraw motion for summary judgment. My attorney at the time never let me know that there were admissions and Interrrogatories and he did not file them. Then he left the firm and I received a motion to withdraw from him. Here comes Midland's atty again. I filed in the clerk's office my answer and affirmative defenses. Also, back in Oct 2009, my attorney filed request for documents. They replied they did not have to have a written contract. Can anyone guide me in how to end this.

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What would I file to get this thrown out due to lack of prosecution? Original summons was in August 2008. Then motion for summary judgment in Oct of 2009. Then motion to withdrawal motion for summary judgment was in Oct 2009. Now they filed for another motion for summary judgement 5 days ago, was supposed to be on 4/5/2012. Now they filed for motion to withdraw motion for summary judgment. Had a lawyer until sept 2011, withdrew as my attorney as he left firm. I am going Pro Se. I filed my own admissions and affirmative defenses a few weeks ago. Then they filed the motion to withdraw. Tired of them bouncing things around. No type of statement or anything with my xxxxx account number. They were asked to produce documents back in oct 2009 when I attorney then filed an answer and affirmative defenses. They stayed low until they got the motion that my attorney had withdrawn. Any suggestions?

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