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Tonight’s Agenda:

1. Interrogatories
2. Request to Produce
3. Request for Admission
4. Motions to Compel
5. Motions for Sanctions
6. Motions in Limine

The devil is in the details. The details in litigation lie basically in discovery — asking and responding. Very few pro se litigants know how to construct good Interrogatories, Requests to Produce, or Requests for Admission. They know even less about how to use the responses, if they get any.

And they know still less about how to use inconsistencies or lack of response as the basis for enforcement and motions for contempt and sanctions and ultimately to limit the evidence that can be introduced by the claimant in foreclosure.

Failure to know about this is fatal because it is failure to understand the nature and procedure of litigation. Most lawyers don’t suffer from that ignorance. But they often do suffer from lack of motivation and thus they head for failure when they could be heading for success.

Judges are getting increasingly irritated by sloppy and bad discovery practices by both sides in litigation.

See Exterro-EDRM Judges Survey 2019 Series-…iscovery Specialists (ACEDS) – JDSupra

Filed under: burden of persuasion, burden of pleading, BURDEN OF PROOF, CORRUPTION, discovery, Discovery -Subpoena, evidence, Fabrication of documents, foreclosure, foreclosure defenses, Mortgage, Motions, Pleading, prima facie case, Servicer, sham transactions |