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 […]

Tags: compelling discovery, garmin factors, interrogatories, production of documents, request for admissions, request to produce
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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 […]

Tags: request for admissions
Posted in bubble, Corruption, Eviction, securities fraud |

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 […]

Tags: Bank of America, Bank of America foreclosure, bankruptcy, best foreclosure lawyers in Florida, borrower, countrywide, disclosure, discovery, foreclosure, foreclosure defense, foreclosure offense, foreclosure summary judgment, foreclosures, fraud, LOAN MODIFICATION, modification, Palm Bay, quiet title, request for admissions, rescission, RESPA, securitization, TILA audit, trial strategy, trustee, WEISBAND, winning foreclosure trials
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  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 […]

Tags: affifrmative defenses, allonge, assignment, bankrupty, beneficiary, cloud on title, DEED OF TRUST, defenses, discovery, interrogatories, invalid deed of trust, invalid mortgage deed, Investigation, lack of standing, lawsuit, MERS, money judgment, mortgage deed, motion for contempt, motion to lift stay, motion to strike pleadings, motion tocompel, notice of deposition, real financial interest, request for access, request for admissions, request toproduce, RESPA, standing, TILA, unsecured loan, unsecured obligationunsecured note, void deed of trust, void mortgage deed
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This is reply to a question which has been posed to us recently by several readers through email and at least one comment. We have advised demanding the alleged lender (the one suing you in foreclosure or who has scheduled the sale) allow you to inspect and provide you copies of original documents so they […]

Tags: deposition duces tecum, foreclosure, foreclosure defense, foreclosure offense, interrogatories, lost document, lost note, Mortgage, original document, request for admissions, request for production
Posted in bubble, Eviction |