james24

My 2nd Time against JDB!

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Need help to beat a JDB. just need to answer special ROGS. I need to beat them! i got exhausted with my first battle and ended up losing up to the appeals. Thank you in advance! need a better way to answer these questions.

 

1.  did you ever submit a request for credit account to GE capital retail bank? i had chevron card though.

2.  did GE capital retail bank issue a credit account number xxxx-xxx-xx  in your name?

3. State the approximate date you open the credit account.

4.  identify each and every person other than yourself who has ever had the possession of any credit card for the credit account.

5.  identify each and every person who you ever authorized to use the credit account.

6. Did you use the credit account?

7. is $1,043,  the amount set forth in the complaint in this case as the sum owed as of February 26, 2014, your balance due as of that date on the credit account?

8. if you do not agree that $1,043,  the amount set forth in the complaint in this case as the sum owed, is your balance due is February 26, 2014 on the credit account, state all facts upon which you base your denial that the sum of $1043 is your balance due as of February 26, 2014 on the credit account.

9.  did you have a report to GE capital retail bank that the credit card for the credit account was lost or stolen?

10.  Did you ever report in writing to GE capital retail bank or portfolio recovery associates that there was any problem with the credit account, which problem remains unresolved?

11.  Did you receive periodic statements from GE capital retail bank regarding the credit account?

12.  State approximate date of your last payment to GE capital retail bank on the credit account.

13.  Have you ever corresponded with GE capital retail bank in writing regarding the credit account.

14.  Have you ever corresponded with portfolio recovery Associates in writing regarding the credit account?

15.  State all facts upon which you base your denial of the complaint in this action.

16.  State all facts upon which you base each affirmative defenses to the complaint in this action.

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Need help to beat a JDB. just need to answer special ROGS. I need to beat them! i got exhausted with my first battle and ended up losing up to the appeals. Thank you in advance! need a better way to answer these questions.

 

1.  did you ever submit a request for credit account to GE capital retail bank? i had chevron card though.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

2.  did GE capital retail bank issue a credit account number xxxx-xxx-xx  in your name?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

 

3. State the approximate date you open the credit account.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

4.  identify each and every person other than yourself who has ever had the possession of any credit card for the credit account.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

5.  identify each and every person who you ever authorized to use the credit account.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

6. Did you use the credit account?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

7. is $1,043,  the amount set forth in the complaint in this case as the sum owed as of February 26, 2014, your balance due as of that date on the credit account?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

8. if you do not agree that $1,043,  the amount set forth in the complaint in this case as the sum owed, is your balance due is February 26, 2014 on the credit account, state all facts upon which you base your denial that the sum of $1043 is your balance due as of February 26, 2014 on the credit account.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

9.  did you have a report to GE capital retail bank that the credit card for the credit account was lost or stolen?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

10.  Did you ever report in writing to GE capital retail bank or portfolio recovery associates that there was any problem with the credit account, which problem remains unresolved?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

11.  Did you receive periodic statements from GE capital retail bank regarding the credit account?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

12.  State approximate date of your last payment to GE capital retail bank on the credit account.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

13.  Have you ever corresponded with GE capital retail bank in writing regarding the credit account.

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations.

14.  Have you ever corresponded with portfolio recovery Associates in writing regarding the credit account?

 

Defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations (unless you DV'd).

15.  State all facts upon which you base your denial of the complaint in this action.

 

Defendant is without sufficient information upon which to base answers to claims, as plaintiff has failed to present sufficient information or clarification for defendant formulate a proper response

 

16.  State all facts upon which you base each affirmative defenses to the complaint in this action.

 

Defendant is without any information upon which to base any affirmative defenses in plaintiffs claims, as plaintiff has failed to present sufficient information with their petition upon which to determine such defenses

but Defendant reserves the right to amend and/or add Answers, Defenses and/or Counter Claims at a later date should more definitive information become available.

 

General Denial I hope on your answer, only admited your name and address if its ask,,,,,deny every thing else! .This is just an opening shot. You won't get dinged for it as you have the right to amend or change your answers at any time on a motion, if you admitted something you shouldn't have AMEND it!. Make them have to cough up more documentation. Get busy and prepare your interrogatories, admissions, and request for documents. Check your time to respond, Watch your response and THEIR response times, mark on calender.

 

As they've just sent you their interrogatories and admissions, get YOUR's ready. When your ready to send your answer to these introgs and addmissions, file or send yours to them too. You need to make them cough up what they've got...chances are what little they send back will be all they have. The quicker you make them cough up, the longer you may have to formulate your offensive-defense and find plenty of statutes and as many case's to cite that apply as you can..Google Scholar is your free friend.........................You have to make your response as likely to be true as they make theirs.................Remember one thing......don't forget...they are the moving party and the burden is on them to PROVE they have a case.......I don't care what kind of affidavit or affiant they have, 99% of the time they don't qualify the "expert" affiant to make the affidavit, the affidavit rarely list or mentions their "other" proof, like Bill of Sale, Monthly statements, Spreadsheet files (which to be a business records must be sworn, testified to or certified by the O.C and specified by an O.C. affiant or witness. not the JDB..Statutes-CASE Law), without the Forward Flow agreement (terms and condition of the sale of accounts) most things are deficient in some manner..a good point to drive at, because they NORMALLY will fight to keep that out (if they don't attack the heck out of it too!....need case law to define why exhibits need it or are deficient ). Attack the Affiant's job, qualifications, documents consulted as basis for his claims, attack any items he FAILS to identify, attack the one's he does harder. Without a verified, qualified affiant to attest to the reliability and accuracy of those unlisted items is merely heresay, cite your state's heresay statutes learn your state rules of evidence.

 

After they file their MSJ......................and they will, they have to. No money in it if they don't.

 

Basically take EACH item of evidence--one by one, EACH shady statements of facts and twisting of truth they make--paragraph by paragraph....make an argument against their statements backed up by all the case law and/or statutes to support it you can find that apply. against them. Show that their proof is unreliable, not trustworthy ......then you MUST Object to each one, Make a motion to stirke each piece. Remember, create an argument against the affidavit AND especially the chain of ownership........If they can't prove they own it....Everything else is immaterial.........no ownership.....no standing.............NO right to sue or collect........Successor in Interest (ownership) and Affidavits are your key choke points! Make them lose those two and unless the Judge and Plaintiff are in Bed or at the Golf course together you should prevail....also no ownership will make claim of Account Stated immaterial.......should. But I guarantee if you do little to nothing, your toast, done turn you over.

 

But remember............OBJECT to their statement of facts + case law+statute+arguments= Motion to Strike.....OBJECT to documents+case law+ statutes+arguments.= Motion to Strike.......Without doing these things IF you lose the MSJ your done, you don't got nuthin for appeal but dumb luck.....................Raise these Objections and IF you lose the MSJ you have a very good basis for a possible reversal at appeal (which you usually have to ask for) unless your state has a de novo review of MSJ like OK (and those Objections and Strikes are Extremely important....it makes them look and evaluate) and it never hurts to ask anyway.

 

Main thing is..............prepare to fight, Prepare to fight Hard for Dismissal! (with prejudice if at all possible fight for it)...take what you can! Prepare for MSJ Appeal as you argue your case, just in case Murphy shows up, do you best to preserve issues!.

 

Helpful items, get on your states court site learn to find other JDB case's, IF you can find one that the defendant won or won with an attorney handling it, examine their submissions, examine several of the petitions, motions, citations, etc., JDB filings, observe the progression of their MSJ briefs a good guide for responses.......find a good NACA lawyer in your area or state(if its not in the cards to hire one), look up their similar JDB cases, see how they plead, how they format those pleadings.....copy anything and every you need to help your case.....its all public record and little these JDB do is really original..

 

Seems like a lot, but it is mainly a mind frame to get into and stay in, can't afford to think like a consumer, think like the Collector and reverse engineer it.. It will require quite a bit of extra effort, we don't have paralegals and law intern's to do the grunt work.

 

Hope that helps you kick off and gets you started........Use your mistakes as a guide of what NOT to do.

 

It would greatly help anyone help you further if you would search for Racecar's 20 questions, and answer them. Redact your complaint and answers and post them too. That way people will have a better idea and not be floundering around.

 

My help is generic to a degree....there are many here from CA that can be more specific on your state forms and requirements.............you may have to "frame" my answers above somewhat different in CA, but the gist of it is to not admit or provide them anything they can hang their hats on.

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Thank you guys. You should've seen my first battle. I was able to discredit the witness jdb brought in and yet the judge admitted the ccp 98! How can somebody who was discredited in person have a different result on her affidavit. Man, that was very depressing.

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Did you object to the ccp98 in your last case?

In any event, you still need to answer these ROGs (which was your question). Did you send discovery request or demand for a BOP to them yet? (Need to know this before tackling these ROGs).

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I requested bop earlier in the trial. They denied saying way to early to request for it and gave a bit of statement of accounts. And yesterday i just got their ccp 98 just when i got done with the response for rogs,admission, request for documents and planning to send it to them today. I objected to the ccp and judge even agreed witness cant testify since she doesnt work for the OC. Looked like i was gonna win. But judge looked the other way.

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@saytar, you cannot use lack of information to answer, an answer like that will either get them admitted, or you can get a compel motion, or sanctions.

Most courts have rules on how you can answer.

Need help to beat a JDB. just need to answer special ROGS. I need to beat them! i got exhausted with my first battle and ended up losing up to the appeals. Thank you in advance! need a better way to answer these questions.

1. did you ever submit a request for credit account to GE capital retail bank? i had chevron card though.

No. After a reasonable inquiry and diligent search defendant has no records of an account with GE capitol bank.

2. did GE capital retail bank issue a credit account number xxxx-xxx-xx in your name?

After a reasonable inquiry and diligent search defendant has no records that would indicate he had an account with GE capitol with the account number xxxx.

3. State the approximate date you open the credit account.

after a reasonable inquiry and diligent search defendant has no records for the alleged account in question.

4. identify each and every person other than yourself who has ever had the possession of any credit card for the credit account.

None. After a reasonable inquiry and diligent search defendant denies he had possession of alleged card.

5. identify each and every person who you ever authorized to use the credit account.

None. Same answer as 4.

6. Did you use the credit account?

after a reasonable inquiry and diligent search defendant has no records supporting the use and authorization of alleged credit account.

7. is $1,043, the amount set forth in the complaint in this case as the sum owed as of February 26, 2014, your balance due as of that date on the credit account?

after a reasonable inquiry and diligent search defendant has no record of alleged account. Question calls for a conclusion as to an amount owed on an account , defendant denies account.

8. if you do not agree that $1,043, the amount set forth in the complaint in this case as the sum owed, is your balance due is February 26, 2014 on the credit account, state all facts upon which you base your denial that the sum of $1043 is your balance due as of February 26, 2014 on the credit account.

Same as 7.

9. did you have a report to GE capital retail bank that the credit card for the credit account was lost or stolen?

After a reasonable inquiry and diligent search defendant has no records of this alleged account therefore would not have reported it as lost or stolen.

10. Did you ever report in writing to GE capital retail bank or portfolio recovery associates that there was any problem with the credit account, which problem remains unresolved?

After a reasonable inquiry and diligent search defendant has no supporting records of alleged account therefore he would not have contacted alleged creditor with problems. Defendant denies alleged account

eTC. You have to say I checked and I can't find any records verses the send me the proof then I'll tell you route. Yes they have to prove the account, but you are required to answer their discovery and "help them" so to speak. If you can't find any supporting documentation, then you can't help them. Plus you are a terrible record keeper who saves nothing.

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. Looked like i was gonna win. But judge looked the other way.

Do you have a different judge this time? If you don't know, find out. You can get a different judge if necessary.

 

Also, are you done answering their discovery, or do you still need help?

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My plan today is to send my responses together with ccp 96 although i just got their ccp 98 yesterday. Planning to send subpoena for the witness who gave the lawyers office in san jose ca. Any other suggestions? I got exhausted on the last battle that i kinda forgot the steps i took coz i dragged them up to the appeals. Thanks people here!

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My plan today is to send my responses together with ccp 96 although i just got their ccp 98 yesterday. Planning to send subpoena for the witness who gave the lawyers office in san jose ca. Any other suggestions? I got exhausted on the last battle that i kinda forgot the steps i took coz i dragged them up to the appeals. Thanks people here!

Don't send them together or they will claim they didn't notice the ccp 96 request was included or something to that effect. Make sure your timing is correct here. CCP 96 to be sent no sooner than 45 calendar days before trial and no later than 30 calendar days before trial. Send them CMRRR.

 

Check the distance of the lawyers office. Is it within 150 miles of the court?

 

And find out if you have the same judge from last time.

 

Try not to burn yourself out, focus on the important steps, and ask if you have a question.

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@Anon Amos, i am gonna work on @shellieh98 suggested then submit all my response together with ccp 96 today because they sent a letter that they should have it by Feb 16. Since I have the ccp98, i should start working on MIL and Declaration in support of it. Any new inputs since you did yours? maybe like citing new cases that beat JDBs? Thank you!

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@Anon Amos, i should start working on MIL and Declaration in support of it. Any new inputs since you did yours? maybe like citing new cases that beat JDBs? Thank you!

Calawyer has suggested labeling it as an "objection" rather than an MIL. Also there is now case law on this. Target v Rocha and CACH v Rodgers (look those up and give them the correct citations).

 

I would think you have evidence to object to as well, and make sure you know the rules and case law for no affidavits at trial (I think you know this stuff, nothings changed, your judge just blew it last time).

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Calawyer has suggested labeling it as an "objection" rather than an MIL. Also there is now case law on this. Target v Rocha and CACH v Rodgers (look those up and give them the correct citations).

 

I would think you have evidence to object to as well, and make sure you know the rules and case law for no affidavits at trial (I think you know this stuff, nothings changed, your judge just blew it last time).

Shoot! trial date is March 24. I counted, less than 30 calendar days before trial already for ccp 96. What will be the title heading for the MIL? OBJECTION TO CCP 98? Lawyer's office is less than 150miles. but that will be receiving  subpoena in behalf, like they always do.  Definitely a different judge. I am trying to retrace my steps so whatever i did correct on this case that made me win can be a blueprint just like @astmedics How I beat midland post, only this can be the updated version with Target vs rocha and rodgers v cache.

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Shoot! trial date is March 24. I counted, less than 30 calendar days before trial already for ccp 96. What will be the title heading for the MIL? OBJECTION TO CCP 98?

You could overnight mail the ccp 96. If it's too late and you already sent it, don't worry about it (they may not object to it). Just don't make any more mistakes (at least no critical ones).

 

The heading would be "DEFENDANTS OBJECTION TO CCP 98 DECLARATION IN LIEU OF LIVE TESTIMONY OF JOE BOTTOM FEEDER" or something to that effect. You title it as an objection to whatever they are calling their declaration, using their title and name of declarant etc.

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What's the best way to answer these?

 

11.  Did you receive periodic statements from GE capital retail bank regarding the credit account?

 

 

12.  State approximate date of your last payment to GE capital retail bank on the credit account.

 

 

13.  Have you ever corresponded with GE capital retail bank in writing regarding the credit account.

 

 

14.  Have you ever corresponded with portfolio recovery Associates in writing regarding the credit account?

 

 

15.  State all facts upon which you base your denial of the complaint in this action.

 

 

16.  State all facts upon which you base each affirmative defenses to the complaint in this action.

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What's the best way to answer these?

 

11.  Did you receive periodic statements from GE capital retail bank regarding the credit account?

 

 Objection, in part and to the extent that thus request seeks for the conclusion that such statements were mailed. Without waving defendants objection, Defendant denies.

12.  State approximate date of your last payment to GE capital retail bank on the credit account.

 

Objection, this request seeks for the conclusion that defendat made any payments to the alleged account. Without waving defendants objection, defendant denies. (Unless of course you are stating SOL as an affirmative defense.)

 

13.  Have you ever corresponded with GE capital retail bank in writing regarding the credit account.

 

Objection, this request seeks for the conclusuon that defendant had any knowledge of any alleged account. Without waiving said objection Defendant denies.

14.  Have you ever corresponded with portfolio recovery Associates in writing regarding the credit account?

 

defendant denies initiating any correspondence with plaintiff prior ti the commencement of this motion. (Unless of course you have).

15.  State all facts upon which you base your denial of the complaint in this action.

 

 

16.  State all facts upon which you base each affirmative defenses to the complaint in this action.

(What are the affirmative defenses you stated?)

Ive seen these same question around here that calawyer has assisted in ansering. Im sure you will find them, i want to say that calgirl2012 may have them in her threat but dont remember for sure.

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What's the best way to answer these?

 

11.  Did you receive periodic statements from GE capital retail bank regarding the credit account?

 

After a reasonable inquiry and diligent search defendant has no records of any billing statements from GE Capitol, no.

 

12.  State approximate date of your last payment to GE capital retail bank on the credit account.

After a reasonable inquiry and diligent search defendant has no records of any payments to ge capitol. Furthermore this interagorratory assumes payments were made, where defendant has denied knowledge of alleged account.

 

 

13.  Have you ever corresponded with GE capital retail bank in writing regarding the credit account.

No correspondence with GE capitol concerning this alleged account if it exists.

 

 

14.  Have you ever corresponded with portfolio recovery Associates in writing regarding the credit account?

Defendant unaware of alleged account and has no coorespondance with portfolio recovery associates untill the filing of this lawsuit. (Unless they sent you a letter, then change that)

 

 

15.  State all facts upon which you base your denial of the complaint in this action.

Defendant has no records of this alleged account if it exists. Plaintiff has not shown they have standing to sue if this alleged account exists.

 

 

16.  State all facts upon which you base each affirmative defenses to the complaint in this action.

Same as above.

If you file a bunch of objections without answering the question, they will just state why it is reveal ant, and compel you to answer. Very few Rogs can you use objections and get away with it, unless it is for things like personal info, bank records, things like that. The more you can answer without objecting without helping your case, the better. By answering you have no records, you don't recall the account, you are not saying it isn't yours, you are saying you have a poor memory and without records that show you had one, you have no clue. Better to be a dumb shyt than to make their case for them.

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Hello, I am writing my trial brief, how can i best point out that the witness is using "in care of" address to receive the subpoena? I know CACH v Rodgers and Target V Rocha, i just want to make sure i hit the nail on the head. I want to win this case. also i am looking at the bill of sale, they sent 3 copies but each has signatures of people. i mean, shouldn't a contract be signed by signatories in one document and not separately? what is the best way to point out trust worthiness of the document. here is the link to the Bill of Sale. Trial date is March 20, what date can i send the subpoena? is it 20 calendar days before trial or 20 business days before trial. thank you very much! @calawyer @Seadragon @Anon Amos @HomelessInCalifornia @shellieh98

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Hello, I am writing my trial brief, how can i best point out that the witness is using "in care of" address to receive the subpoena? also i am looking at the bill of sale, they sent 3 copies but each has signatures of people. i mean, shouldn't a contract be signed by signatories in one document and not separately? what is the best way to point out trust worthiness of the document. here is the link of the Bill of Sale. Trial date is March 20, what date can i send the subpoena? is it 20 calendar days before trial or 20 business days before trial. thank you very much! 

 

You've partially answered your own question here...i am looking at the bill of sale, they sent 3 copies but each has signatures of people. i mean, shouldn't a contract be signed by signatories in one document and not separately.

Signatures of people...hmmmm the janitor, maid, window washer's??????? These people identified and authenticated to be legally able to sign the documents? What document are they signing for....what is the best way to point out trust worthiness of the documentI' I'm willing to bet it mentions some document not provided to the court by plaintiff's............like "the Agreement"   ????? Look under your civil procedures for expert witness's, requirements of business documents (just saying so...don't make it so)...documents submitted must be sworn to, certified, or supported by affidavit..sure your statutes or some case law in CA will lay that out...wrap that part of arguments around them.....How can one tell if what they say or signed to is correct without the document referenced......what are they signing to, condition of items, price, merchantability, etc....

 

Everybody lately seems to just be accepting that whatever the JDB sends is proof absolute....... :ah:ah:ah:   Usually most of it is NOT...the job is to be able to lead the court to that absolute conclusion with good arguments, supported by statute and case law when possible....not just grand statements.

 

California Code - Chapter 2: EXCEPTIONS TO THE HEARSAY RULE

 

 

See what I'm pointing too???? Just examine the documents, lack of any referenced document, documents in hand not mentioned, sworn to, supporting affidavit or certified by notary.....all of these are question's needing answered, you just need to find statutes, and citations that define this need to be answered and wrap you arguments around them.....create material issues of facts, things that only a properly authenticated witness could answer.....

 

Here it is calender days with a holiday on the due date a freebie.....Date Caluclator   Might work for CA too. Check your rules for any extra days allowed due to type of service...mail, courier, etc.... usually get a day or so for mailing add to it......some states have to have it by date, some will go by cancellation date on envelope....Go OCD on the evidence..or lack thereof.

 

how can i best point out that the witness is using "in care of" address to receive the subpoena?  find the statute that defines proper and improper address's for witness's, .......I'm pretty sure that CA, defines that pretty specifically, much better than some..I've seen many CA poster's comment's on that very subject.......Say so....Then state it as possibly an Objection to what the witness would be saying if you could find them to serve them.

 

Good luck in any case!

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Recite the part in target vs rocha where service must be personal. Is the address within 150 miles of the court? You would still try to serve them personally at that addy.

The bill of sale references a purchase agreement that is not attached. Did they attach a loan schedule with your name on it? See if it says the JDB printed it, that is a self serving document if so.

Any other affidavits in the evidence they sent you? Remember affidavits are not admissible in ca if objected to. (Elkins vs someone, you need to look that up ). Also they must contain the phrase under california penalty they swear to xxxx, if that is not on it, you can strike it.

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Recite the part in target vs rocha where service must be personal. Is the address within 150 miles of the court? You would still try to serve them personally at that addy.

The bill of sale references a purchase agreement that is not attached. Did they attach a loan schedule with your name on it? See if it says the JDB printed it, that is a self serving document if so.

Any other affidavits in the evidence they sent you? Remember affidavits are not admissible in ca if objected to. (Elkins vs someone, you need to look that up ). Also they must contain the phrase under california penalty they swear to xxxx, if that is not on it, you can strike it.

Agreed. read and cite CCP 1987 (witnesses must be personally served).

 

Hearsay (affidavits) inadmissible at trial CA Evidence Code 1200. Elkins v Superior Court. There are several other cases to cite on hearsay as well in the footnotes of the Elkins case (James 24 remind me later if I don't get back to you with the other case law). 

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