Pleadings and Motions

Pro Se Defendant’s Response to Debt Buyer Motion for Summary Judgment

DEFENDANT’S RESPONSE IN OPPOSITION TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND BRIEF IN SUPPORT COMES NOW the Defendant, <<DEFENDANT>>, and files this Response in Opposition to Plaintiffs Motion for Summary Judgment and Brief in Support thereof pursuant to O.C.G.A. § 9-11-56(e) and shows that the Court should deny Plaintiffs’ Motion for Summary Judgment. In support […]

Georgia Request for Admissions to Plaintiff Junk Debt Buyer

When sending your own discovery requests to junk debt buyers while in litigation, you might consider using Request for Admissions.  It’s like getting to the bottom of the matter and figuring out which facts are agreed upon.  Remember, they can send Request for Admissions to you too.  They will want you to make certain admissions […]

Interrogatories to Plaintiff Junk Debt Buyer

Interrogatories are written questions asked of the opposing party.  The answers should be “verified”.  Interrogatories are questions asked under oath and a verification should accompany the responses.  This is basically a signed document that is returned to you along with the written answer.  This signed document should be that of the Plaintiff, for example, an employee or […]

Request for Production of Documents to Plaintiff Junk Debt Buyer

I’ve read through many examples of discovery to junk debt buyers and am always surprised at how voluminous and off point they can sometimes be.  Forget about being all fancy pants – if you’re not a lawyer, don’t act like one.  Don’t draw up discovery you can’t understand yourself, its worthless.  Remember, there is no discovery in Magistrate court! Some of the more […]

§ 9-11-50. Motions for directed verdict

O.C.G.A.  § 9-11-50.  Motions for directed verdict and for judgment notwithstanding the verdict The directed verdict is a good tool for any pro se to have in their court room skills if they know just enough to poke holes in a plaintiff junk debt buyer’s case but not quite enough to stand on their own and present […]

§9-11-41 Dismissal of actions; recommencement within six months

O.C.G.A. § 9-11-41.  Dismissal of actions; recommencement within six months (a)  Voluntary dismissal; effect (1)  By plaintiff; by stipulation. Subject to the provisions of subsection (e) of Code Section 9-11-23, Code Section 9-11-66, and any statute, an action may be dismissed by the plaintiff, without order or permission of court: (A) By filing a written notice of dismissal […]

Georgia Civil Practice Act O.C.G.A. § 9-11-33 Interrogatories

The following is an excerpt of O.C.G.A. § 9-11-33 and demonstrate the “rules” placed upon Interrogatories in Discovery.  Generally, the Civil Practice Act and Discovery does not apply to Magistrate Court proceedings. TITLE 9.  CIVIL PRACTICE CHAPTER 11.  CIVIL PRACTICE ACT ARTICLE 5.  DEPOSITIONS AND DISCOVERY O.C.G.A. § 9-11-33 (a)  Availability; procedures for use. (1) Any party may serve upon any other party written […]