The Night of A Thousand Motions

Talk about an an attention grabbing title!

Hmmmmmmmmmmmmm!

Well, at least I've managed to maintain my self-amusing sense of humor.
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How to respond to this new FDLG's filing?

What to do?

YIKES!

Mind racing with all kinds of possibilities and tactics, with the undertow of anxiety as a constant presence. Knowing that I am in way over my head, but also sure that I could NEVER dream of affording excellent, qualified, experienced legal representation.

Ah, I suppose this is "DIY" (Do It Yourself) at it's finest?

-Motion to Compel with Request for Expenses?
-Motion to Overrule Objections to Defendant's Productions?
-Second Motion for Productions?
-Response in Opposition to Plaintiff's Motion for Summary Judgment?
-Affidavit in Response to Plaintiff's Motion for Summary Judgment?
-Motion to Determine Sufficiency of Answers to Admissions and to Deem Admissions -Admitted
-Motion to Strike Affidavit of Amounts Due and Owing?
-Second Request for Admissions?

Ha! One would think I know what the heck I'm talking about when I use all those legal titles!

I did fax a nice letter to opposing counsel in case I decide to file the Motion to Overrule Plaintiff's Objections to Defendant's Productions. Supposedly, Judges hate dealing with discovery issues and like to see everyone attempting to play nicey-nice! Plus, the Florida Rules of Civil Procedure (NOTE: all Pro Ses must find their state's Rules of Civil Procedure as a guide to civil court conduct.)

I am in receipt of your September 30, 2009 filing of a Response to Defendant’s Request for Production.

Your Response made numerous general objections, most of which were repetitive and not applicable to the individual productions requests. More importantly, with regard to the individual productions, your filing made either baseless objections or provided incomplete or non-responsive answers; ie: willingness to produce a copy but no mention of producing the requested original Promissory Note and Mortgage.

Please reconsider your objections to my request for production of documents, the 8 of the 13 admissions to which you objected and also to respond to the Interrogatories, to which there has no response whatsoever. I anticipate we can address these issues amicably, without unnecessarily involving the overburdened court system.

Please note that my requests are well within the scope of and are reasonably calculated to lead to discovery of admissible evidence as the information sought thereby pertains to the specific issues listed in your Complaint.

Thank you for your attention to this important matter.

Sincerely,
Lisa, Pro Se
Faxed: _______________________
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