request for admissions

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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NEW FORM FOR REQUESTS FOR ADMISSIONS IN CALIFORNIA

In responding to an attorney request, I thought the end product, while not perfect, was worthy of sharing with our readers, especially the lawyers and paralegals. Hat tip to Dan Hanecek who wrote most of it. In compliance with Code of Civil Procedure Section 2033.220, each response to the requests for admission shall: (a)                          Admit …

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WINNING FORECLOSURE TRIALS: BOA Loses Another One in Brevard County Florida

MOST POPULAR ARTICLES GET COMBO TITLE AND SECURITIZATION ANALYSIS – CLICK HERE FOLLOW THE MONEY TRAIL Editor’s Comment: Here is a firm that believes the Banks don’t have the goods and is willing to go after it. They also show some courage and tenacity in going on the offensive, which is where all of the …

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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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