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should I have received CCP98?


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Trial is 8/29. Have not received anything from the plaintiff since their response to request for BOP. CCP98 says they need to serve upon me a copy of the testimony and an address where I can serve a supoena on the witness, right? Maybe I'll see it here soon, but it seems like the 30 day deadline would be somewhere around now if I understand correctly. 

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yeah sent CMRR, USPS site is down but was delivered a day or two after being sent i believe. You're right they have 20 days.

 

Wouldn't they have to send the CCP98 info to me 30 days before trial even if I did not send CCP96? that way I have my 20 days to supoena regardless if they still have time for CCP96 response

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CAL. CCP. CODE § 98 : California Code - Section 98

A party may, in lieu of presenting direct testimony, offer the prepared testimony of revelant witnesses in the form of affidavits or declarations under penalty of perjury. The prepared testimony may include, but need not be limited to, the opinions of expert witnesses, and testimony which authenticates documentary evidence. To the extent the contents of the prepared testimony would have been admissible were the witness to testify orally thereto, the prepared testimony shall be received as evidence in the case, provided that either of the following applies:

( a ) A copy has been served on the party against whom it is offered at least 30 days prior to the trial, together with a current address of the affiant that is within 150 miles of the place of trial, and the affiant is available for service of process at that place for a reasonable period of time, during the 20 days immediately prior to trial.

( b )The statement is in the form of all or part of a deposition in the case, and the party against whom it is offered had an opportunity to participate in the deposition.

The court shall determine whether the affidavit or declaration shall be read into the record in lieu of oral testimony or admitted as a documentary exhibit.

Here's the specifics of the CCP98 requirements. "A" specifically states it must be sent to you at least 30 days before trial. So my thinking is this; if they fail to send one, well, I think that's a good thing. It means they will have to have a witness from the OC present during the trial and you will be able to question them.

And, when they respond to the CCP96 and include a witness (though I thought they weren't required to list witnesses...something about it not being required and something about impeachment. I've never understood that part of it so I'm hoping somebody with a better handle on the impeachment thing will explain that.) but, in the even they do list any, you can attempt to have them personally subpoenaed at the attorney's address, but only allow personal service. Any chance they listed possible witnesses at any point in the case?

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nope no witness list, no discovery from them, no evidence other than a screenshot of their software showing my account in response to request for BOP. CCP96 form includes a requirement to list all witnesses. I'll wait and see what the CCP96 response says I guess, and would assume if they try to submit the in leiu of testimony at trial I can object on the grounds that I did not receive a copy.

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They don't HAVE to send a ccp98; if they don't plan on using one, which would be highly unlikely. Anyway, TOMORROW is the deadline for them. You have to receive it 30 days before trial; anytime past that makes it inadmissible.

Any response to your CCP96 to them after the 20 day deadline will also be inadmissible.

Good Luck.

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Ya they don't have to use a CCP 98. They could use a live witness rather than the CCP 98 but that is rare. They sound like they are/were just out for a default and didn't intend to fight back. If they don't respond to the CCP 96 they will be dead in the water.

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They don't HAVE to send a ccp98; if they don't plan on using one, which would be highly unlikely. Anyway, TOMORROW is the deadline for them. You have to receive it 30 days before trial; anytime past that makes it inadmissible.

 

 

No.  Plaintiff has to serve it 30 days before trial.  That means put it in the mailbox on that date.  It will therefore be received a few days later.

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