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Motion to Preclude Needed.

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I filled counterclaims against a JDB(FCDPA,FCRA, multiple violations of state laws). I requested Bill of Sale, among other documents.



As expected, the JDB either Objected or said it was too much of a burden. I am looking for help filling my motion to Preclude(a template would be very helpful), also would I need to file this motion in person at the court?

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