Boiler Plate Objections from Banks Under Attack from Federal Courts

After constant complaints from litigants and lawyers on the length, breadth, and costs of discovery, there seems to be a real effort afoot to solve all three of these problems. The upcoming amendments to the Federal Rules of Civil Procedure, which go into effect on December 1, 2015, aim to decrease what have become the most expensive and time-consuming aspects of litigation.

One of the many ways that the amendments will do this is by expressly adopting what many courts have already done–barring the use of generalized boilerplate objections in responding to document requests. The use of such objections often results in a meaningless first round (or several rounds) of discovery before anything productive is actually accomplished. As amended, the Rules aim to preclude the use of these types of objections, resulting in faster progress in discovery and with a little less costly back-and-forth.

As amended, Rule 34 should eliminate the all too common practice of dumping kitchen sink objections into the initial written responses to document requests. For example, under the current Rules, it is not unusual for an attorney to list every conceivable objection to a set of document requests in an introduction, “incorporate by reference” those objections into each specific response, and then repeat the more applicable (though still generalized and boilerplate) objections in the specific responses. The attorney then concludes each response with an entirely unhelpful statement along the lines of, “any non-objectionable, non-privileged documents responsive to this request will be produced at a mutually agreed upon date and time.”

See http://www.jdsupra.com/legalnews/an-end-to-the-kitchen-sink-approach-to-41238/

 

19 Responses

  1. FC is STATE RUN TERRORISM by STATE OFFICIALS who have no badge on & no LEGAL JURISDICTION.

    Furthermore, they have no legal right to join or work on behalf of FEDERAL BANKING REGULATORS because that’s legal evidence of TAX EVASION by their own unlawful behest to DESTROY LEGAL EVIDENCE they’re IDENTITY THEFT criminals.

  2. Their psyche war begins when you find out they’re crooks who planned to try & undermine you.

    They want no TITLE HOLDERS except for their criminal selves so they try & terrorize their victims with their criminal evilness.

    You tell them they’re crooks & they will
    manufacture things & ways to try & steal your FREE WILL.

    Hospice does it everydsy to people, they send in their BLACK HAND HORROR SHOW.

    I saw them come unlawfully for my Grandparents & it’s undignified & disgraceful what they do to try & legitimize their DRUG CULT OF DEATH.

  3. JUDGE LISA MARINO had the nerve to say to me in COOK COUNTY CHANCERY COURT last year if i’m still living in my own house.

    I told her Yes, it’s my house.

    Either she’s completely oblivious to the law & has no law degree or shes on some heavy narcotics, or
    probably both.

    Where was she when I was bringing up my 4 kids here?

    She clearly has some VENDETTA here.

    She should be formally interrogated by FEDERAL OFFICIALS for instgating herself into the private lives of U.S. CITIZENS.

  4. UNFAIR SURPRISE the FEDERAL RESERVE BANK operates from the demonic realm.

    If we knew thst we would have called the exorcist to rep us in FRAUDCLOSURE.

  5. Their evil empire can’t function to it’s own irrythmic beat without mass criminal deception.

    http://www.lifeinthemix.co.uk/contact_us.html

  6. Their GINORMOUS DEBT FRAUD can never be repaid because they keep creating more of it.

    CRIME SYNDICATES don’t operate on budgets they keep robbing everyone else.

    Thet can’t use their DIRECT ENERGY WEAPONS of MASS DESTRUCTION effectively enough unless they FALSE IMPRISON the MORAL MAJORITY to their old SURNERO-AKKADIAN MYSTERY RELIGION.

    It’s SATANISM in its most pristime form & why RELIGIOUS PERSECUTION is their modus operandi.

  7. I’ve seen the FEDERAL STOCK BROKER PROTECTION RING first hand.

    The open debauchery of our legal right to privacy began way before CAPITAL ONE warned in one of their commercials they’ve come to pillage.

    I went to FIRST MIDWEST BANK AMPITHEATER in south suburban CHICAGO to see one DAVE MATTHEWS concert with my teenage kids.

    There were young people in the lawn venue openly having sex & doing drugs right in front of “SECURITY” who did nothing.

  8. instead of the FEDERAL COPS doing tbeir job they’ve let the STREET THUGS take their unlawful rogue brand of WAR CRIMES to trial on the streets of our great nation.

    You csn’t be party to the same crimes you engaged in & engage in more crimes to cover that up in the COURTHOUSES otherwise they need to declare war.

    Then close down the Government because it’s not our Government.

  9. @iwantmynpv,

    There are said to be 600 Trillion that are public- out in the open.
    There are said to be an additional 600 Trillion that are concealed- likely operating as proceeds from private deals- can anyone say, “hidden Trusts”.

    I frankly, don’t see how it is possible to pay down 1200 Trillion Dollars.

    The “Deficit”, everybody is always squawking about is around 16 Trillion and that number only speaks for the “interest” on our debt, (beside the 1200 Trillion owed to international, phony, “insurance swaps”, AKA “Notional” derivatives).

    The criminals have created a “catch-22” where they believe they are above the LAW, do to the deleterious effects any prosecution will cause within international financial markets. The “catch-22” they have created is also perceived, by the criminals, as working in their favor because they have hyper-inflated US Currency while targeting the pension plans.

    I have spoken to people from Wall Street –sadly, they live nearby- and they basically suggested nobody from law enforcement is anxious to expose the fact the pension plans are insolvent. One guy said, “The cops will never do anything because too many people would be affected”.

    I say, the LAW must prevail or it is only a matter of time before the chickens come home to roost.

    In other words, if We stand idly-by and watch our currency destroyed by a privately-owned, criminal, banking cartel, masquerading as a “Federal” entity, then We deserve to be reduced to victimhood.

    Frankly, the “Federal Reserve” is a criminal FARCE; it doesn’t speak for “We The People” and it never did; moreover, it isn’t the government. It has only managed to manipulate the government by forcing money into our elections, as an example. And both parties are rotten.

    Bill Clinton and 3 Republican Senators, Graham, Leach and Bliley created the “ACT” that will forever bear their name. That “ACT” suppressed Glass-Steagall and allowed the criminal banking elites to essentially create the scams that are now operating to steal American homes…

    Incidentally, those scams were put in place so that the criminal, banking elites could use American Homes to launder TERRORIST AND DRUG CARTEL MONEY!

    What part doesn’t Law Enforcement understand as “ILLEGAL”?

    The “principal” owed on our debt has not been “paid down” since Andrew Jackson first threw the money-changers out of the financial affairs of this country when he shut down the second central banking experiment. (Google Nicholas Biddle).

    The only way I can see to resolve the hyper-inflationary state of the bogus currency (“Federal Reserve Notes”), is to begin the prosecutions and get to the bottom of all of the bogus “Trusts”.

    As those phony deals are unwound, the new American Currency (the “Greenback”, as an example), can be issued through settlements to the victims on a pro-rated basis.

    In other words, there are gazillions of, now-discredited, “Federal Reserve Notes” floating around in the criminal bubble created by the criminal elites from Wall Street, among other places, and there are also gazillions of defrauded American Taxpayers…

    So, recapture those discredited, hyper-inflationary, “Federal Reserve Notes” and replace them with the new currency, while it is issued in the presence of the rule of LAW.

  10. @michael keane – does that number include the synthetic swaps? Also the banks now prefer to be called globalist, versus international, its’s an image thing.

    What we all missed during the explosions and murders by the terror crew… China was quietly stuck into the SDR Bucket and the Yuan is now a reserve currency.

    American’s must push to pay down the federal debt now. We cannot afford the interest payments, and issue new debt to cover the debt service on the old debt. Our ability to issue new credit to the corporate US lies in the hands of the Federal Reserve Bank, and its international handlers.

    By 2020 the Yuan will be the most widely held currency, Fact Fact Fact.

  11. There is wantoned lack of want for CRIMINAL PROSECUTION for the MORTGAGE FRAUD.

    That is victimization of us by the FEDERAL PROSECUTORS whose job it is to enforce the law.

    Clearly there is unlawful conflict of issues & that is called mass CORRUPTION.

  12. There is no logical explanation for fraudulent documents being recorded upon REAL PROPERTY TITLES by no one knows who or why they were even recorded.

    How do redacted copies & supposed docs with scratch outs get by the COUNTY CLERKS?

    They showed me on the screen the fraud, but did not say how it got recorded.

    Someone blogged you can record whatever you want.

    I would not imagine that would include fraud.

    Why would someone want to record that?

    That is evidence of one vast criminal conspiracy.

    One fraudulent doc recorded would be the end to FC but that is being willfully ignored by the judges.

  13. They never secured the legal liens, therefore they were planning something sinister IMHO.

  14. Their AUDITING FIRMS cook the books for them & cover it up too.

  15. They’re operating under false ID’s & they’re not going to reveal who they’re really subbing for.

    It’s probably their AUDUTING FIRMS.

  16. — TONIGHT —
    A gentle reminder – please make an appointment for yourself to join us for Episode [9] on our 1 Hour follow-up Q&A call TONIGHT – Thursday evening at 6:45 PM Eastern – This is right after Neil’s weekly Thursday Night 30 Min call at 6 PM Eastern.
    [Calls and Chat Board are recorded for review and sharing… feel free to go back and hear or download recordings]

    Details follow:

    1) Neil’s Living Lies Call at 6:00PM Eastern (347) 850-1260… on Blogtalk Radio

    2) Our interactive Q&A call, “Garfield’s Goose & Friends” on TalkShoe with your host, greg – begins every Thursday night at 6:45PM Eastern, 15 minutes after the conclusion of Neil’s show

    Hope everyone had a great Thanksgiving Break.
    Tonight we’ll recap recent headlines in foreclosure and homeowners victories against bad bankers…

    Call in at (724) 444-7444 (then use Call ID: 139335) then “1#” for guest
    and/or use your computer to blog/type at http://www.talkshoe.com/tc/139335
    6:45 PM Eastern Thursdays (for 60 min)

    Please use the phone line TO SPEAK; ASK QUESTIONS AND CONTRIBUTE…
    computer access will ONLY allow you to hear and type into the blog (Not Speak)…

    all are welcome!

    if you would like to receive a weekly email reminder of the call… please email the host at: [lawman@gmx.us]
    – with the subject line: “please add me to the goose!”
    – to be removed from the mailing list use the subject line: “please remove me from the goose!”

    intro: 2015-11-12
    Welcome Everyone to Episode 8 of the Neil Garfield Q&A after-show here on Talkshoe #139335… humorously entitled “Garfield’s Goose & Friends”

    This call is not associated with Neil, living lies, or his law firm or other interests….
    It is the sole responsibility of the Friends of Neil Garfield

    I’m your host Greg, coming to you live from the birthplace of the American Bar Association, and the home of Abraham Lincoln, Al Capone, the Untouchables, and Operation Greylord… where the motto is “vote early – vote often”😉

    ***
    This is a one hour program in which we hope some questions and answers relating to discussions on the living lies blog might be addressed…

    The primary focus of this call is to discuss Mortgage Foreclosure Defense and Attack strategies and related experiences…

    No official accounting or legal advice is given herein
    If you need a lawyer or CPA, please hire one authorized to work in your state…

    ***
    We will start the call out with everyone muted, so –
    To raise your hand to speak, press * 8 and you will be placed into the cue and brought into the call in the order of your request

    Thank you all for being here… let’s help each other…

    So….. where – shall we begin?

  17. i are not a lawyer, but…

    It seems to me those of us under threat should notice, through certified mail, any evidence of Fraud in our possession.

    18 U.S. Code § 4 – Misprision of felony | US Law |…

    http://www.law.cornell.edu › … › Title 18 › Part I › Chapter 1

    Whoever, having knowledge of the actual commission of a felony cognizable by a court of the United States, conceals and does not as soon as possible make known the …

    … Judges, Prosecutors, local police chiefs, the “Oathkeeper” in your local Sherriff’s Department, the local bar association, the local chamber of commerce, local realtors (particularly those engaged in stealing your property), the group trying to steal your property (those bidding on your house, for example)…

    I think a certified letter should also go to the lawyer filth representing the banker filth trying to steal your house.

    Again, i are not a lawyer.

    Look, the fraudsters used OPM, other people’s money to pay off your “loan”. Every single bank on the planet manipulated the LIBOR…

    They told you the interest rate was one thing- let’s say, 5%- then they changed the rate- either at the closing- or, behind your back…

    It is already proven they manipulated the LIBOR (Google it)- if they did it behind your back- they switched the rate to favor their bank- for example, if they told you 5%, they then had their underwriters adjust it to, let’s say, 3%…

    So, the banks collected the difference….

    For the duration of the loan.

    They didn’t get caught…

    And they destroyed the paper…

    So, the banks took the “loans” somebody else already paid them for and entered them into hidden “Trusts” (Google Bucketeering)…

    Those criminal “Trusts” are now vacationing in the islands along with TRILLIONS OWED, (WALMART, AS AN EXAMPLE IS SHELTERING SOME 80 BILLION DOLLARS, OFFSHORE) AS TAXES DENIED, WE THE PEOPLE, BY THE NEW FACIST ELITES: THE “CORPORATISTS”.

    The people that paid for the “loans” (institutional investors, like PENSION PLANS, as an example), have been deceived, all along, because they are third parties to the hidden “Bucket Trusts”…

    And so are YOU…

    YOU are a third party to their criminal Frauds, except they are using your name and property to conceal their behaviors.

    As THIRD PARTIES, BOTH: THE “INVESTORS” AND THE “BORROWERS” NEVER GET TO THE TRUTH BECAUSE THE BANKS OWN THE GOVERNMENT.

    The courts tell you you can’t get discovery because you are a third party. They have also been told, by a private, international banking cartel, operating out of your intentionally mislabeled “Federal Reserve”, that the “TRUTH” will destroy the American Dollar as the international “Sovereign Currency”.

    HOGWASH. CONCEALING THIS CRIMINAL BEHAVIOR WILL DESTROY OUR COUNTRY AND THE ONLY CHANCE OUR DOLLAR HAS IS TO EXPOSE THIS GLARING CRIMINAL BEHAVIOR.

    EVERY COUNTRY ON THE PLANET KNOWS THE AMERICAN ELECTORATE IS SUBJECT TO A MANIPULATIVE, CRIMINAL HYPOCRISY.

    BUT… not Mitt Romney and his Fascist, “Corporatist” playmates… “Corporations are people, my friend”… AGAIN HOGWASH, with a capital “HOG”.

    So, now the banks, in the wake of subprime lending (where they absolutely destroyed themselves), refuse to show their-total-assets-minus-their-total-liabilities- the technical term is the “M3”. It hasn’t been reported since 2006.

    Recognizing their subprime nonsense has destroyed them: they are INSOLVENT… The banks then placed phony insurance “bets” on their multiplicity of FRAUDULENT “LOANS”. These are the DERIVATIVES…

    PRESENTLY, THERE ARE 1200 TRILLION DOLLARS (GOOGLE “QUADRILLION”) OWED, INTERNATIONALLY, TO THE PRIVATELY-OWNED, INTERNATIONAL, BANKING CONSPIRACY THAT IS: “CENTRAL BANKING”.

    These “Notional Derivatives” are the last, best hope for the Fascists manipulating OUR CURRENCY and STEALING OUR HOMES.

    This country, through the original “TEA PARTY” in Boston Harbor is derived as a direct renunciation to an international, Fascist, “Corporatocracy”; in Boston Harbor, the colonists rebelled, specifically against, the British, East India “TEA” Company.

    It is past time the American Electorate roused itself to remember what is truly at stake… and it isn’t hot dogs on the Fourth of July.

  18. Reblogged this on California Freelance Paralegal and commented:
    It is about time that the Courts do something about big banks and other litigants that abuse the discovery process with boilerplate objections.

  19. Yes, the discovery issue is egregious and does not serve justice and due process. I know this from experience. Now, in my state and most states, the state courts follow the Federal Rules of Civil Procedure with their state rules. We will see how long it takes for the state courts to change discovery rules to emulate FRCP.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: