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Somewhere In So Cal

Being Sued by Barclays Bank Delaware via Suttell & Hammer

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Case is aged over 500 days. Super slow going through the system. I've responded to summons and round of discovery/ request for admissions. Just recently received an "At Issue Memorandum". Looks like we're getting into the final rounds here. Any advice on how to respond to their "Memorandum"? Is it best to just respond with a Counter Memorandum saying "Nah- not ready for trial, because I got some discovery for youse." ?


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