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Hi,

 

I have been sued by Hunt and Henriques, and it's now around 35 days until Trial. Since I am a senior citizen and in bad health, I am looking for any kind of help I can get with drafting a motion to continue trial due to my health condition. I can barely walk even with a walker, and have numerous other physical conditions and am wondering if those would be valid grounds to get a continuance. Also, I have a question on how to object to one of Plaintiff's requests in their RPD (the CCP1987 one). The first two, I think I can handle, but the third has left me confused.

 

But, first, here is the lawsuit background:

 

1. Who is the named plaintiff in the suit? Citibank, N.A.

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) 
Hunt & Henriques


3. How much are you being sued for? in the neighborhood of $6,000
4. Who is the original creditor? (if not the Plaintiff) Citibank (South Dakota), N.A.

5. How do you know you are being sued? (You were served, right?) Found out on Court's online site after someone unknown showed at my door. I did not answer the door that time. Strangely, the process server never stopped by again, but filed a proof of service with the Court, nonetheless. Sadly, I lacked knowledge at the time to file a motion to quash service, so I filed an answer and stated in one of my affirmative defenses that I was improperly served.

6. How were you served? (Mail, In person, Notice on door) I was not. I think they call that 'sewer service'

7. Was the service legal as required by your state? It wasn't legal, but I am guessing it is too late now.

Process Service Requirements by State - Summons Complaint

8. What was your correspondence (if any) with the people suing you before you think you were being sued? I may have sent a debt validation letter, but I am not sure.

9. What state and county do you live in? Sacramento County, Sacramento California

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) the Plaintiff is alleging 2010, but they sued in 2011, unfortunately.

11. What is the SOL on the debt? in California, 4 years, but the lawsuit stopped the clock.

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or      looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). 
Complaint, Summons and Proof of Service filed

Answer Filed

Long Period of inactivity

CCP 98 Declaration Filed (without a trial date or me even sending a CCP 96)

Another period of inactivity

Plaintiff files a Limited Status Case Memorandum and gets a Trial Date

At this point, I served some discovery on them (Form Rogs and request for documents as set one, then Request for Admissions as set two).

They have responded to the Form Rogs and request for documents, and still need to respond to request for admissions).

Then, I sent them a CCP 96 request (I think around 42-43 days before Trial) and the Objection to their CCP 98 (since they had filed it with Court).

The day they got the CCP 96 request for me and the object, their Lawyer sent their own CCP 96 via overnight delivery and has also sent me a notice to compel appearance and produce documents (CCP section 1987).


13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No.

14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. I might have, but I honestly don't remember. My memory has really gotten downhill with my age.

15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? 

 

Responded within 30 days back when I was sued. They sued on Common Counts/Account stated. Plaintiff never sent any discovery to me.

 

16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits.

 

Nothing. But they sent years worth of credit card statements as responses to my discovery requests. They have also sent a CCP98 declaration in lieu by Dorothy Ruiz, which was the one I objected to.

 

****

 

I have really wanted to hire a Lawyer but have no income to do so. I am over 70 years old and in poor health, and ther is nothing for the creditor to take. I get by with help from my family. I think it really is the sense of pride that keeps me from wanting to stop them from getting a judgment. Aside from needing help in regards to writing a motion to request continuance (can I base it on grounds of my illness as well as wanting to retain a pro-bono attorney, if I ever find one?), I am unsure how to respond to Plaintiff's request to produce documents (CCP 1987). There are 3 requests, and I have attempted to respond to #1 and #2, but the #3 is the one that is giving me a lot of trouble.

 

Here are the requests and my responses:

 

  1. REQUEST NO. 1: All documents sent by defendant to plaintiff regarding defendant's credit account with Plaintiff.

  2. RESPONSE TO REQUEST NO. 1: Objection. Documents of this sort should already be in control of the Plaintiff. Plaintiff is on a fishing expedition. Burden of proof in this case rests on Plaintiff. The production of all documents sent by Defendant to Plaintiff is overly broad, as the case to date has many documents. The making of copies for Plaintiff who have all the same documents from the case file would create undue burden for Defendant who has limited resources.

  3. REQUEST NO. 2: All documents sent by plaintiff to defendant regarding defendant's credit account with plaintiff.

  4. RESPONSE TO REQUEST NO. 2: Objection. Documents of this sort should already be in control of the Plaintiff. Plaintiff is on a fishing expedition. Burden of proof in this case rests on Plaintiff. The production of all documents sent by Plaintiff to Defendant is overly broad as the case to date has many documents. The making of copies for Plaintiff who have all the same documents from the case file would create undue burden for Defendant who has limited resources.

  5. REQUEST NO. 3: All documents supporting the affirmative defenses alleged by defendant.

  6. RESPONSE TO REQUEST NO. 3: ?????  (I do not know how to answer this one)

 

Thanks!

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@DefendingSenior

 

 

  1. REQUEST NO. 1: All documents sent by defendant to plaintiff regarding defendant's credit account with Plaintiff.

  2. RESPONSE TO REQUEST NO. 1: Objection. Documents of this sort should already be in control of the Plaintiff. Plaintiff is on a fishing expedition. Burden of proof in this case rests on Plaintiff. The production of all documents sent by Defendant to Plaintiff is overly broad, as the case to date has many documents. The making of copies for Plaintiff who have all the same documents from the case file would create undue burden for Defendant who has limited resources.

 

 

 

 

Did you ever send any documents to the plaintiff?

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Since I am a senior citizen and in bad health, I am looking for any kind of help I can get with drafting a motion to continue trial due to my health condition. I can barely walk even with a walker, and have numerous other physical conditions and am wondering if those would be valid grounds to get a continuance.

 

It's an uphill battle for continuance, but take a look at CRC 3.1332 for an idea of what's required.  Is there any way you can assure the court that your health should be improved enough to better allow you to participate at trial if a continuance is granted?

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It's an uphill battle for continuance, but take a look at CRC 3.1332 for an idea of what's required.  Is there any way you can assure the court that your health should be improved enough to better allow you to participate at trial if a continuance is granted?

 

I would say that a couple of health issues are much more acute than the others, and I will be seeing a specialist regarding those around that similar time when the trial takes place. With some of those issues resolved and improved, I could be in a definitely better shape to attend the Trial. Seeing how it may take a few months to deal with the current issues, I was thinking of mentioning in my motion for continuance that I could be available in November/December time-frame.

 

Now, my understanding is that I have to write a notice of motion, a motion and my declaration. I feel a bit hesitant to go into details of my own illness in the declaration itself (it is a public record, after all), but if leave it too vague, then I'm running a chance of my motion being denied. Also, do lawyers for the debt collectors frequently oppose motions for continuance or not? Do they ever subpoeana Defendant's medical records, etc?

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Did you state any affirmative defenses in your answer to the complaint?

 

Yes, I did. They mostly were the standard ones such as "The complaint fails to state a claim upon which relief may be granted", along with Laches, Principle of Waiver, Statue of frauds, usury and the others. I did state in one my affirmative defenses that I wasn't served the summons, but I am not sure how I would go about proving that. Can I say something like "The defendant has not received the Complain and the Summons and therefore cannot bring them to Court"?

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No, the proper thing to do would have been a motion to quash, but you answered so it is a moot point now. In answering that rog, you used affirmative defenses that shifted the burden of proof on you. They want to know what you have that caused you to used those defenses. I don't know what if anything you have, but could answer with "after a reasonable inquiry and diligent search the defendant has none of the requested documents. If any of the requested documents become available, defendant will supplement at that time. Discovery is still ongoing."

REQUEST NO. 1: All documents sent by defendant to plaintiff regarding defendant's credit account with Plaintiff.

RESPONSE TO REQUEST NO. After a reasonable inquiry and diligent search defendant has none of the requested documents. Plaintiff assumes an account where one has not been identified. Defendant will supplement should any documents become available.

No. 2 rog add

REQUEST NO. 2: All documents sent by plaintiff to defendant regarding defendant's credit account with plaintiff.

Without waiving forgoing objection defendant states he has no additional documents to add to what plaintiff has already sent regarding the alleged account in question.

You don't really want to object to Rogs, as the court can make you answer. If you do object, you should always say without waiving .......and then answer with something they can't use. If you don't have any docs...you don't have any so they can't make you produce.. They try and trick you into admitting the account also with questions especially if you denied the account in your answer, so you have to be careful.

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No, the proper thing to do would have been a motion to quash, but you answered so it is a moot point now. In answering that rog, you used affirmative defenses that shifted the burden of proof on you. They want to know what you have that caused you to used those defenses. I don't know what if anything you have, but could answer with "after a reasonable inquiry and diligent search the defendant has none of the requested documents. If any of the requested documents become available, defendant will supplement at that time. Discovery is still ongoing."

REQUEST NO. 1: All documents sent by defendant to plaintiff regarding defendant's credit account with Plaintiff.

RESPONSE TO REQUEST NO. After a reasonable inquiry and diligent search defendant has none of the requested documents. Plaintiff assumes an account where one has not been identified. Defendant will supplement should any documents become available.

No. 2 rog add

REQUEST NO. 2: All documents sent by plaintiff to defendant regarding defendant's credit account with plaintiff.

Without waiving forgoing objection defendant states he has no additional documents to add to what plaintiff has already sent regarding the alleged account in question.

You don't really want to object to Rogs, as the court can make you answer. If you do object, you should always say without waiving .......and then answer with something they can't use. If you don't have any docs...you don't have any so they can't make you produce.. They try and trick you into admitting the account also with questions especially if you denied the account in your answer, so you have to be careful.

 

Thank you for your help! It makes so much more sense now. Yes, I have definitely made some mistakes on this and in the other part of my case that I am not too proud of, but, before sending, I at least got rid of this part:

 

 

The production of all documents sent by Defendant to Plaintiff is overly broad, as the case to date has many documents. The making of copies for Plaintiff who have all the same documents from the case file would create undue burden for Defendant who has limited resources.

 

since it seemed incriminating. Instead, I went with this:

 

REQUEST NO. 1: All documents sent by defendant to plaintiff regarding defendant's credit account with Plaintiff.

RESPONSE TO REQUEST NO. 1: Objection. Documents of this sort should already be in control of the Plaintiff. Plaintiff is on a fishing expedition. Burden of proof in this case rests on Plaintiff. The request is overly broad, oppressive and burdensome. The request is also vague and ambiguous since it does not specify or define what sorts of documents are being sought. The Plaintiff has also not defined what they consider to be documents, and the Defendant is unable to comply as a result.

 

REQUEST NO. 2: All documents sent by plaintiff to defendant regarding defendant's credit account with plaintiff.

RESPONSE TO REQUEST NO. 2: Objection. Documents of this sort should already be in control of the Plaintiff. Plaintiff is on a fishing expedition. Burden of proof in this case rests on Plaintiff. The request is overly broad, oppressive and burdensome. The request is also vague and ambiguous since it does not specify or define what sorts of documents are being sought. The Plaintiff has also not defined what they consider to be documents, and the Defendant is unable to comply as a result.

 

REQUEST NO. 3: All documents supporting the affirmative defenses alleged by defendant.

RESPONSE TO REQUEST NO. 3: Objection. The request is overly broad, oppressive and burdensome. The request is also vague and ambiguous as it does not state what documents are being sought in regards to what affirmative defenses. The Plaintiff has also not defined what they consider to be documents, and the Defendant is unable to comply as a result.

So the question is:

If they make me answer these ROG's at the witness stand, can I just tell them I had no documents (I actually don't) right then and there?

Another, unrelated question is on their CCP 98 Declaration in lieu. The Plaintiff sent this one to me early. Way too early (Something like last year). There are only 33 calendar days to Trial, and I have heard that they cannot introduce a new CCP 98 Declaration in lieu if it is less than 30 days before the trial. Is that true? Since their CCP 98 Declaration in lieu was filed with the Court, I have also filed my objection. If they do not introduce the new CCP 98 Declaration in lieu within the time allotted, are they stuck with that particular CCP 98 Declaration in lieu they have on file?

Also, about the proof of service:

I have read on this forum that the best approach is to have their CCP 98 witness subpoenaed. But they are sure making it really costly on me since their Affiant has given the Plaintiff Counsel's Law Office as her address. The trouble is that the Law Office is almost 130 miles from where I live. Does that mean I'd need to drive to the other city  to give subpoena over to the process server in that city. Also, since I have so much trouble walking these days, is it ok to get the subpoena form complete but send a family member to the Courthouse to get it issued? Or is that something only I can do in person?

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If they make me answer these ROG's at the witness stand, can I just tell them I had no documents (I actually don't) right then and there?

Clarification: these are Requests for Production (not Interrogatories), right?

 

 

Another, unrelated question is on their CCP 98 Declaration in lieu. The Plaintiff sent this one to me early. Way too early (Something like last year). There are only 33 calendar days to Trial, and I have heard that they cannot introduce a new CCP 98 Declaration in lieu if it is less than 30 days before the trial. Is that true? Since their CCP 98 Declaration in lieu was filed with the Court, I have also filed my objection. If they do not introduce the new CCP 98 Declaration in lieu within the time allotted, are they stuck with that particular CCP 98 Declaration in lieu they have on file?

I'm unaware of anything that would make a ccp98 declaration "too early" - it has to be served "at least 30 days prior to the trial."

 

 

Also, about the proof of service:

I have read on this forum that the best approach is to have their CCP 98 witness subpoenaed. But they are sure making it really costly on me since their Affiant has given the Plaintiff Counsel's Law Office as her address. The trouble is that the Law Office is almost 130 miles from where I live. Does that mean I'd need to drive to the other city  to give subpoena over to the process server in that city.

 Is the address within 150 miles of court?  You can use a process server near you and have them make the drive, or (likely much less expensive) you can mail the subpoena to a process server closer to the address of service.

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You can have a non interested party serve the subpoena, such as a friend, and they file a due diligence form. The nice thing about using a process server is if they say I don't believe them, you would be covered if you used one rather than a friend wh they may muddy the waters and insist he come to court.

Now remember even though they are an original creditor, they still need a witness if you object to their affidavidt. This is where I don't know the right Cali codes, @AnonAmos does, but I think it is called a ccp1987 in your case where you subpoena the oc person. Not real clear, but anon will know.

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@DefendingSenior, I just got a dismissal without prejudice from H & H. They sent me a CCP 98 with the "Dec in Lieu" & I paid a process server to serve a subpoena to their authorized agent (ABC Legal). Well, that person who signed the Dec in Lieu was not able to be PERSONALLY served. With a CCP 98, that person who signed the Declaration has to be personally served & show up to court. These JDB's think that people will not fight and they'll collect an automatic judgment. H & H put in for a dismissal prior to trial. I found out after I filed my motion, declaration, and trial brief. They'd actually dismissed the day before, but the court hadn't updated the web site yet. That's how I found out they'd dismissed.

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@DefendingSenior, yes, that's the form. You have to go to the court & have it stamped prior to having it served (make sure to take two copies so you can keep a stamped copy for yourself). Also, you'll want the person who attempts service to do so AT LEAST 2-3 times (my Process server attempted service twice). Does your CCP 98 say that the declarant will be able to be served 20 days immediately prior to trial? Make sure you do it at least 2-3 times within those 20 days prior to trial. Whomever you get to attempt service, make sure they fill out a declaration of service. Contact your local sheriff department. They'll serve a subpoena for $35 or if you have a fee waiver, it's free. Call to make sure your SD is able to do so (some don't do them anymore). I have a process server I used if you need one. We're all here to help. Good luck.

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Ok, I am almost done with completing the SUBP-001 form but have a few questions:

 

The parts that say "Date Issued" and "Type or Print Name" and "Signature of Person Issuing Subpoena" are all to be filled out by me, right? Also, how about the last line that says "Title"?

 

Is the only place on the subpoena to be filled/stamped by Court the right-hand corner that says "For Court Use Only"?

 

Silly questions, I know. But the Court here accepts the subpoenas via drop-box only (they won't take it at the counter) so I want to make sure I get everything 100% right, as I won't get another chance. Thanks in advance.

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The parts that say "Date Issued" and "Type or Print Name" and "Signature of Person Issuing Subpoena" are all to be filled out by me, right? Also, how about the last line that says "Title"?

 

Nope, each of those will be filled out by the court clerk.

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Nope, each of those will be filled out by the court clerk.

 

Ooops, that would have been a very costly mistake on my part, time-wise. Many thanks for the clarification. I didn't realize this was one of those judicial council forms I do not sign. I was looking at courts.ca.gov for filing instructions, but didn't find much there.

 

I just found this, though:

 

http://www.ehow.com/how_8197869_subpoena-witness-california.html

 

So, the Court is an issuer of the subpoena, and I am the subpoenaing party, right? Also, regarding step #5 in the article above, should the witness be served with the copy of the subpoena or the original?

 

Thanks again!

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Thank you all! I have the subpoena for the CCP98 affiant in my hands and ready to go.

 

Regarding this part of the CCP98:

 

" Pursuant to CCP 98, this affiant is available for service of process: LAW FIRM, c/o LOCAL BUSINESS AND BUSINESS ADDRESS for the 20 days immediately prior to trial."

 

I am trying to figure out how the "20 days immediately before the trial" are calculated. Are those 20 calendar days or 20 court days? Also, when counting backwards from the trial date, is the trial date itself counted or not? Also, how about the Holidays (4th of July in my case)? Do I skip the 4th of July in the calculation?

 

Also, in my case, Plaintiff's CCP98 dec in lieu was filed with the Court long before the Trial was set and I had sent the CCP96 request. Despite this CCP98 dec in lieu being filed with court, I am guessing it still needs to be included in the CCP 96 response, right? I am aware of the 30 days before the trial date deadline rule for the CCP98 declaration, and am wondering if this is 30 calendar days, also.

 

Since I've objected to Plaintiff's CCP98 declaration and managed to file it with Court (this was an evidentiary objection though, not a procedural one), do you think they may send another CCP98 declaration with the new Affiant, of will they stick with the one on file? Not counting today, but counting from tomorrow and including all holidays and the trial date, there are 29 days left until trial. But, I am sure this is not a proper way to calculate.

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Your trial date is Day Zero, count backwards from there. You'll go by calender days (both the 20 day subpoena question & 30 day CCP98 question) - fyi whenever a deadline is going to go by court days, you'll see "court days" specifically written in the code/rule. If a weekend/holiday is in the middle of a calender day calculation, it doesn't affect it.

 

Another fyi - whenever you are working with a deadline period that is calculated by Court Days (local court rules for filing/serving Trial Briefs & MILs are usually done by Court Days), weekends and holidays do not count in that calculation. Court days are specifically days the court is conducting regular business.

 

Whatever CCP98 Declaration/Affidavit they intend to use, it needed to be in the mail by day 30, so they can't surprise you with a new affidavit/person after that 30 day threshold. And yes, I think it still needs to be listed (including name of the Affiant) in their CCP96 response.

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@RyanEX, thanks much for the explanation.

 

I have also received Plaintiff's CCP96 asking me to produce my own witnesses and evidence.

 

Per CaLawyer's advice in here http://www.creditinfocenter.com/community/topic/315256-how-do-i-answer-to-ccp-96-from-a-jdb/,

my response to their CCP96 request will be:

 

"Defendant reserves the right to call witnesses and introduce evidence for impeachment purposes."

 

I realize that the code doesn't require me to respond if I don't have any witnesses or evidence to use other than for impeachment purposes, but am wondering if it is better to send a response anyway. The only question I have is whether I have to sign my own CCP 96 response with the "under the penalty of perjury..." verbiage, or If I just sign and date my response to their CCP96 request.

 

Also, if called upon as a witness at trial (which I am sure they will do, as they are compelling me to attend with CCP 1987), do I need to object right before I am at the witness stand? My understanding is that, being a pro se defendant, once I am on the stand, I am not allowed to object. Or, am I?

 

What would be the grounds to objecting to them calling me to testify? My understanding is that they do need a witness to win the case, and if I have their CCP98 declarant subpoena'd and their CCP98 thrown out of evidence, they could still win by using my own testimony. It seems like a Catch 22 scenario: If I admit that I applied for the credit card and used that card, they may get enough admissions out of me to win the case, but if I am evasive with my answers, this could make the judge angry. It is really this witness part that unnerves me the most. Also, if the Plaintiff's attorney gets rude/yells or anything like that while I am testifying, do I have any recourse?

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I got the Plaintiff's CCP 96 response in the mail today, and they have sent me their CCP98 Declaration in Lieu. However, looking at the postmark on their envelope, the date when it was put in the mail was less than 30 days from trial. So, it would seem that they're not compliant with C.C.P. 98 section a)

 

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.

 

However, they also did send me that very same CCP 98 Declaration in Lieu months ago (I presume as some sort of intimidation tactic), before I even sent a CCP96 request to them. Does this negate their untimely CCP98 the second time around? (Their CCP 96 response was timely (they did respond within 20 days), except for the CCP98 part).

 

Also, they have offered this:

 

In the alternative, Plaintiff may call on or more Custodian of Records who could testify from the business records. At this time, that includes:

 

1.  Judy Delage

2.  Dorothy "Dodie" Ruiz

3.  Brian Billings

3. Steve Sabo

 

These witnesses do not reside in California and may be contacted through the undersigned legal counsel at 151 Bernal Rd. Suite 8, San Jose, CA  95119

 

 

The CCP96 section states

 

You are requested to serve on the undersigned, within 20 days, a statement of: the names and addresses of witnesses (OTHER THAN A PARTY WHO IS AN INDIVIDUAL)

 

The issues is this: The Plaintiff's attorney has stated in the CCP96 response that these witnesses do not reside in California, yet has given his Law Office address as the witnesses' address.

 

I am really bothered by this part:

 

 

These witnesses do not reside in California and may be contacted through the undersigned legal counsel at 151 Bernal Rd. Suite 8, San Jose, CA  95119

 

I am not a Lawyer, but shouldn't due process dictate that Plaintiff' gives me direct access to those witnesses instead of the Plaintiff's Attorney acting like a gatekeeper to the witnesses? Is Plaintiff Attorney's response in violation of CCP96?

 

I could file an objection with the court (there is still time) If my objections here would have any merit.

 

Any suggestions?

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I don't know of any code that limits how early in the process they can serve a CCP98, only that it needs to sent at least 30 days before trial. I think that the copy they sent you months ago could keep them compliant, at least in terms of getting it to you on time. Question: did they serve you that copy (the one from months ago) - did it come with a proof of service?

Now, the legitimacy of this CCP98...that's another story...

You are correct in there being a problem with what they have done with the CCP98. Unless the CCP98 is in the form of a deposition which you were given to option to participate (and that's not the case), then you have the right to cross examine this "witness" at trial. Here is the code:

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.

Obviously if the affiant does not reside in California then they can't possibly have a current address within 150 miles of your court. I'm somewhat surprised that they actually told you they don't reside here. Further, the subpoena you would use is for personal service - it's not meant to be delivered "in care of" some law office, and then the law office will handle getting it to the affiant.

The four people you listed, is one of those the name of the affiant in the CCP98?

Is the Bernal Rd. address the only address they gave in the CCP98?

Do you know what your local rules are for filing Motions In Limine/Objections & Trial Briefs - what is the deadline for filing these before trial?

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