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post judgment NJ Superior Law Div post-judgment discovery


bmwnotthecar
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case is in NJ - Superior Court Law Div Civil action

Judgment over $10K

 

Hi I am interested in getting info on the form of how to proceed with filings in a post-judgment discovery issue. 

Briefly it is a non-contested judgment for fees for association dues.  I don't wish to fight nor challenge this.  I have issues with the plaintiff attorney and discovery issues that I want to bring to the court's attention and our county doesn't give pro bono review for filings of this type. 

 

I have points and the content of the filing drafted but I would appreciate if someone could guide me on the format of the caption and type of pleading.  It would be pro-se at the county, not Trenton. 

 

I returned post-judgment rogs and Plaintiff's counsel basically had a fit and is out for blood (or jail time or maybe both).  About 9 weeks after I filed the rogs I got a notice for deposition at a remote location I can't go to because of personal circumstances.  I'm not employed and there are no garnishable wages nor assets. 

 

Attorney is uncivil during calls and notably obstinate.  I contacted her office and brought up several issues -- including a few FDCPA issues, questions about service non-delivery, why is the dep being scheduled with third-parties where I can't get (no transportation) instead of asking me what she wants added to rogs, etc. only 9 weeks after I returned rogs.  She got the rogs and just then sent me a letter not copied to anyone who usually gets copied that she knows the subpoena answers I gave are not true which is not so.  Last time I talked to her she said if she doesn't get any motion they're going to move to enforce rights and eventually file for arrest for non-appearance. 

 

So I got all my points together and I want to file _____ (motion, request to vacate Order, whatever needed) to bring my points up and have the court decide.  I am just not sure what exactly the operative filing is and if I can request some of the relief without filing a brief to the court on the background or if I can even request the relief I am requesting, namely arbitration because I never got any per NJ condo act.  Another thing I want is since she was the one who accused me of fraud I am entitled to counsel paid by the Plaintiff and I also want to include that in the filing(s) plus the FDCPA points and improper service, etc. along with some issues where she and the grounds manager have been cooking up the idea that I am working (third-party contact not justified in collections).  I have access to the filing forms but just need to know what to call the whole litany : ) Anyone, ideas? 

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