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sample form for summary of judgment please


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Hi all,

 

Collection company sued me and I sent Requests for Production of Documents

And the plaintiff(attorney) sent the same document as initial accusation document with the summons and then I sent Requests for Admissions for each item in my doc requests that they did not produce, but they didn't response within 30days,so it automatically admitted according to like below:

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The rule does not specify a motion, it is automatic. I would use summary judgment to fix this, since they admitted to everything you asked them and therefore have no material facts in dispute.

 

Maryland Rule 2-424 Admission of Facts and Genuineness of Documents

(a) Request for Admission

A party may serve at any time one or more written requests to any other party for the admission of (1) the genuineness of any relevant documents described in or exhibited with the request, or (2) the truth of any relevant matters of fact set forth in the request. Copies of documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying. Each matter of which an admission is requested shall be separately set forth.

(Response

Each matter of which an admission is requested shall be deemed admitted unless, within 30 days after service of the request or within 15 days after the date on which that party's initial pleading or motion is required, whichever is later, the party to whom the request is directed serves a response signed by the party or the party's attorney.

 

 

 

 

 

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, so I need to send the summary of judgment to destory the case, but I have never done this before so I need your help. Could you please show me sample summary of judgment for my case? ( I just need some of main sentences, so one page OK)

 

Thank you,

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