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Trans Union motion to dismiss and email with attorney Donald Bradley, Musick, Peeler & Garrett LLP

I posted the TU motion to dismiss:

6/26/08 TU Motion to Dismiss

I haven’t had time yet to scan and redact their discovery responses, but I got essentially NOTHING but objections.

Here’s the email correspondence with TU attorney Donald Bradley:

Sent: Tuesday, July 08, 2008 1:55 PM
To: Bradley, Donald
Subject: Baker v. Trans Union - discovery issues, extension

Mr. Bradley,

I’d like to know whether you’ll agree to an extension to respond to your motion to dismiss until after I have substantive Trans Union discovery responses and we need to schedule a telephone call to discuss the objections and whatever issues.

I’m available this week after 1 PM, please let me know what works for you,

Christine Baker

Attorney Bradley then gave me legal advice:

Ms. Baker, I usually am agreeable to reasonable extensions, but here I have a hard time understanding the reason for your request.  Trans Union’s motion to dismiss is a pleading motion.  Therefore, discovery has no bearing on the issues the judge is deciding.  In fact, if you were to submit any materials from discovery in an opposition, the judge would disregard them. 

That said, I am willing to discuss your request further.  I also am available generally in the afternoons this week to discuss discovery issues.  Please let me know if and when you would like to talk.

Donald E Bradley
Attorney

Musick, Peeler & Garrett LLP
650 Town Center Drive, Suite 1200
Costa Mesa, CA 92626

My response:

Mr. Bradley,

Please let me know if I can call you tomorrow at 1 PM regarding the discovery issues and whether you’ll agree to an extension until 7/25.  If I don’t have substantive discovery responses by then, I will let the court decide whether discovery is relevant to your motion to dismiss.

I haven’t time to deal with discovery and litigation issues since my nephew is visiting until the 17th to help build my house.

Christine Baker

Attorney Bradley declined my request for extension:

I will be available at 1 pm tomorrow.  At this point, I cannot grant your extension request, though we can certainly discuss it further tomorrow if you like.

Donald E Bradley
Attorney
Musick, Peeler & Garrett LLP

It is AMAZING what scum I’m dealing with.  He’s right there with Focus lawyer Cynthya Fulton.

The Trans Union liars have screwed me so many times, I’ve learned a lot and I will obviously request my extension and I’ve NEVER had a judge decline it.  After all, that’s grounds for appeal and they all know that I’ll appeal.

And if discovery can’t be considered to decide a motion to dismiss, what the hell is it for?  My requests for admissions to Trans Union should be deemed admitted since they failed to answer within 30 days.

Unless TU starts to cooperate, discovery and the bad faith TU objections will be a large part of my objection to the motion to dismiss and I might have to file a motion to compel.