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Motion In Limine Questions re: CCP96 & CCP98

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I have a court date set for next Friday, October 4 and need to get my MILs out asap. Here's my problem - I did not get my CCP 96 in on time. The JDB did not send me a CCP 98 either. 

Based on this, how would I phrase an MIL to formally object to 1) making sure they have someone in person and 2) that person be a person from the OC with knowledge of the account, being that I don't have info from CCP 96 nor CCP 98?

Thanks in advance!

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