Equifax didn't provide any documents with its initial disclosures.

The attorneys in the other case had a fit when I took the Equifax approach and I requested that Judge Broomfield decide at the scheduling hearing for that case. Prior to the hearing we agreed to electronically submitted disclosures, but it appeared to me that it definitely is not ok to simply state that you have documents in your possession without producing these documents.

I finally received a bunch of Equifax docs from their local counsel Rodrick Coffey (also the attorney for Verizon) at the 2/27/06 settlement conference - without any listing or description.

I requested it, was promised a listing, got nothing.

I had missed my deadline for mailing discovery by a few days and Equifax didn't provide any responses except to deny the admissions. I have no idea WHY "all discovery shall be served at least 45 days before the discovery deadline."

I just served my requests so that the defendants would have enough time to respond by the 2/28/06 deadline. According to Equifax, discovery was supposed to be served on the 14th and I served it on the 20th of January.

Last week, Mr. Perling asked me whether I would grant an extension for their motion for summary judgment due to a busy schedule and Passover, that deadline was 4/14/06.

I asked whether they would object if I requested that all deadlines be set back 6 months and he eventually agreed. So I gave him a 2 week extension for his MSJ.

And now I'm going to see whether they'll voluntarily waive the objection for my untimely service of my discovery requests.

I really wish I could read about some other pro se's mistakes and didn't have to screw up everything myself. Since I've never done discovery, I had to wait for their requests - nobody volunteered to help me out with this and since discovery isn't filed with the court I'm totally screwed. There's no way to learn discovery other than to just do it and get railroaded.

My efforts to find an attorney were futile. Live and learn.

Next time I'll insist on minimum of 6 months for discovery. We actually had agreed to a 5/19 deadline for fact discovery during the conference call and judge Wake changed it at the hearing. And of course I'll know next time (yes, I think I'll file some more suits, after all that hassle, I better put to use what I learn) how to submit my questions, although it all seems a waste of time because I have yet to get a meaningful response to any question.

I only get objections. It looks like next time I'll have to object to everything and that's how I'll learn to get rid of the objections. And, hopefully I'll learn how to do depositions and get better results for $2k/day. With lots of luck, the defendants will be reimbursing me.

I already know that I'll be appealing the order regarding the evidence and the credit limits and that's the IMPORTANT stuff.

So that's the upside to this manic schedule.

I'll be posting the Equifax MSJ and other filings and here are the Equifax discovery and initial disclosures

Much of the previous e-mail is posted at the blog: Equifax postings

I decided to post e-mail here now because so much of it is being submitted to the court and it makes it easier for me to see when the attorneys don't reply.