interrogatories

Illusion of Confusion: Dealing with Unresponsive "Responses" in Discovery

The bank playbook is very simple: keep it as complicated as possible. That way the court and even the homeowner will come to rely on what the banks and so-called servicer say about names, places, documents and money. That’s how they sold the initial fraudulent MBS and around 10 million foreclosures. If you had a …

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Garmin factors: Proving Your Need to Force the Opposition to Respond to Discovery Requests

For further information please call 954-495-9867 or 520-405-1688 =========================== see Garmin Factors to Justify Order Compelling Discovery Lawyers Practice Note: Compelling discovery is the most important part of foreclosure defense. The current strategy of the banks is to object to practically everything. Set down their objections for hearing and file a motion to compel. But …

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Livinglies Recalibrates Forensic and Litigation Support Services

Responding to specific requests from lawyers and homeowners, the livinglies store has changed its offering. Www.livingliesstore.com You can still get the old Combo of just a title and securitization report, but we have added some levels and services to meet the demand for our services. Of course pricing has been adjusted to reflect the increased …

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A New Set of Interrogatories:

GET A CONSULT WITH NEIL GARFIELD DENY AND DISCOVER!! INTERROGATORIES: FOLLOWING THE MONEY PLEASE!!! CONSULT WITH ATTORNEY LICENSED IN YOUR JURISDICTION OR THE JURISDICTION IN WHICH THE PROPERTY IS LOCATED BEFORE YOU ACT ON ANYTHING ON THIS BLOG. These need to tweaked to fit your case, but they are a decent first step at getting …

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New Workshop on Motion Practice and Discovery

why-you-should-attend-the-discovery-and-motion-practice-workshop VISIT LIVINGLIES STORE FOR FREE VIDEOS AND OTHER RESOURCES START WINNING CASES!! May 23-24, 2010 2 days. 9am-5pm. Neil F Garfield. CLE credits pending but not promised. Register Now. Seating limited to 18. INCLUDES LUNCH AND EXTENSIVE MANUAL OF FORMS, NARRATIVE AND CASES. An in-depth look at securitized residential mortgages and deeds of trust. …

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Sample Interrogatories

SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION – ESSEX VICINAGE ——————————————————————X                Civil Action Deutsche Bank National Trust Company, As Trustee Of Argent Securities, Inc. Asset Backed Pass Through Certificates, Series 2004-PW1 Docket Number: XXX REQUEST FOR INTERROGATORIES Plaintiff(s), vs. XXX; John Doe, Husband Of XXX                                                                            XXX Avenue Rosedale, NY 11422 Defendant(s)/Pro Se ——————————————————————X REQUEST FOR …

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Florida Orders All Homestead Property Foreclosures into Mediation

See AOSC09-54_Foreclosures. A good step in the right directions. I would add that you should be very careful that you don’t get trapped into the “lender narrative.” The Judges are going to very receptive and even enthusiastic about referring these cases to mediation, so don’t annoy them with motions, pleadings or hearings that attempt to …

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How to Attack MERS and WIN!

  NOW AVAILABLE OF AMAZON/KINDLE! EDITOR’S NOTE:MY WIFE WILL KILL ME IF SHE FINDS OUT I’VE BEEN WORKING. SHHHHHHHHH. This news is irresistible. MERS is all but dead with this single decision (see below). Here are the salient points:   MERS is not a beneficiary even if the mortgage deed or deed of trust states …

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