Here, Brian revisits the subject of April 5, 2024 Q&A Conference about what to do if the judge tips you off that she is looking to kill your case in a Summary Motion. It is all about the Counter Affidavit and using it to shape and form your discovery requests. Fill your discovery requests based on the important proofs of ownership documents, affidavits and assignment or bill of sale documents of the debt collector. When they don't give you what you want, send a five day letter to supplement. Then file your Motion to Compel. The Judge will give you an Order saying the other side must provide proper proof of assignment. Then, we there is a Summary Motion against you and they still have not met their Burden of Proof, present the Court with its own signed Order that they have to provide the assignments of ownership. The Court can't ignore its own Order and rule against you if they did not comply. You gotta see three steps down the road and this does it. Good luck.

This video includes the following documents/templates:

• Motion to compel discovery

• Affidavit for answer and discovery on motion to compel

• Defendant Discovery

• Letter to supplement motion to compel

• Motion to compel discovery for Velocity

• Motion to compel discovery for CitiBank

• Show notes

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