[redpilltaker]

First things first....



Decide if jurisdiction and venue are applicable....(I know that COULD be difficult with all the talk about status of being and such....)



And just get your answer back in time....



Your answer should deny each allegation...and then at the end you list your affirmative defenses(plaintiff's unclean hands, fraudulent contract(man, would sure like to get that in there without tipping them off too much about your understanding of the real world...)and a counterclaim...



I am thinking that it is during the discovery phase that you will level both barrels and tear them apart....



So, you're right, address each paragraph of the complaint, and remember "I don't know" is a valid answer...or even, "I have no way to determine that, so allegation is denied..." THEY are the moving party in this right?...



DO NOT show them any of the tools in your tool box until the discovery phase. That is when it will be fun...interogatories, admissions, production of documents, production of all parties with names, addresses and phone numbers who EVER touched your original promissary notes...WOW...yes, that is when the fun will start....



The amount of information/data that they HAVE to produce for you during discovery is mind boggling....sit down, get your aswer to the complaint ready, and get ready for at least a year's worth of involvement....with this website and wumarkus...man, they don't have a chance!!



You know...Tom Schauf's secret banker's manual has always had my interest...any folks out there ever get a chance to read through it?



What for $275...I have been leaning towards buying it myself...just to see if it has ANYTHING in it that I hadn't seen before....



Another idea...does anyone have an actual and official copy of the Credit River Decision?



That is another thing that I was contemplating ordering from the court system in MN. If the actual case had all of the transcripts from the court proceedings when Daley(spelling) had his banker on the stand...it would be great stuff in both potential questions during a trial...AND interrogatories and admissions....



Dude, I will be watching you closely since I am still trying to draft my plan from begining to end....I already know that I live in a strict foreclosure state...so this will be interesting...



Blessings,



RPT





I am editing this because I just reread the prior posts....VERY good points, and all will be useful...at the appropriate time....get an answer in....the scheduling conference is a none issue...the plaintiff's attorney will probably speak to you on the phone, send you a draft, then one to sign to send into the judge....these guys can be(and should be) surprisingly courteous....then as I said above, then the fun part starts as you start building the small box that they will try to squirm out of....if you keep your wits about you, I expect that they will hang themselves....



PEACE....