Defendants: Case Study

Whereas, the District’s participation in this Agreement is not an admission of liability but is an attempt to bring closure to disputed issues; and

1. Defendant PhxCap, LLC (referred to below as the “Landlord”), is and at all times mentioned in this complaint was a limited liability company, with its principal place of business located in Encinitas, California. Defendant is the owner of the property located at 1380 Garnet Avenue, San Diego, California, 92109 (referred to below as the “Project”).

“Concise and clear pleadings are vital to the administration of justice. No party should be called upon to answer or defend the redundant, jumbled and cryptic pleadings filed by plaintiff’s counsel, and no court should be forced to expend so much time and energy attempting to decipher them.” Id. at 949.

Appellant’s dwelling was a prefabricated home located upon a 5-acre lot which contains the home as well as several other buildings. (ADD. 9.) It is located at the end of 264th Street, all of which comprises a unique property. Appellant testified that to restore his Property to a pre-damage condition, it would require a prefabricated “like” home to be added to the Property. (ADD. 28.) Appellant produced an estimate for the “like” home. (ADD. 40-41.)

12. Neither admit nor deny: the Plaintiff stated that he “…discovered on the County of San Joaquin website that a construction case was filed against…” him but we are not sure how exactly he made this effort if the City of Stockton had not given him any notices.

Q. What are the Plaintiffs’ counsel’s responses to “Hearsay” objections that may be raised by the City’s Attorney.

The second part of the brief is the facts of the case. This is the summary or background that led to this particular dispute. It resembles a journalist’s report offering only the basic “who, what, where, when, how and why” of the trial and case record leading up to the present appeal. Included in this is a brief statement of the plaintiff’s argument and the defendant’s argument.

There are a number of parties in this case. I’ll refer to the main parties as the plaintiff and defendant

As a result of the foregoing, an actual controversy has arisen and now exists between plaintiffs and defendants DPR concerning their respective rights and duties. Plaintiffs contend that their security interests in the collateral described in the security agreements continued notwithstanding the sale or disposition to defendants DPR of the collateral, and continue to this day or, alternatively, defendants DPR should be estopped from asserting any right, title, or interest in the collateral senior or adverse to the security interests of plaintiffs in that recognition of any priority interest by defendants DPR would sanction fraud and promote injustice because recognition would effectively render plaintiffs’ security interest illusory, thus allowing

As you are aware, this office represents Gerry and Mary Goldman in this matter. Please note that our clients have informed us that you have contacted them directly without this office’s permission by serving them with your Notice of Videotaped Discovery Depositions, which you signed. As you are also aware, your direct contact with our clients is improper. Please do not contact my client directly unless you receive instruction from this office to do so.

In order to avoid repetition, the defendant refer to facts of case mentioned in statement of claim ,however it is necessary before defense and response hereinafter upholding lack of prima facie evidence mentioned and cited by the claimant especially for the contract which is being claimed made by parts contrary to facts as will be mentioned hereinafter.

Plaintiffs were in contact with SELECT PORTFOLIO SERVICING, INC. (“SPS”) and were attempting to obtain a loan modification, cure the default and retain possession of their Residence. Plaintiffs had discussions and/or received letters from multiple employees and agents of Defendants SPS and CLEAR RECON, including, but not limited to Lusi Talil, Maile Fehoko, Natalie Hutson, Heidi Buckner, Gilbert Beltran, and Carissa Ewing, in violation of Civil Code section 2923.7.

NOW COMES defendant Iron Country Management, Inc., by and through its attorneys, Garan Lucow Miller, P.C., and pursuant to MCR 2.310 and MCR 2.314 hereby requests that plaintiff produce and permit counsel for the defendant, or someone acting on defense counsel's behalf, to inspect and copy the following documents:

agreed to what happened, and the dispute is about attaching a label to the defendants action, but as