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Attorney Kaminski, Partner and Chair of the Financial Services and Class Action Group, Carlson & Messer LLP, is a GENIUS!

He just got himself an extra week for their discovery responses by submitting ONLY objections to my Midland Funding and Midland Credit Management discovery requests.

Their responses were due on 9/3, on the eve of 9/4 they filed their notice of service with the court and I suspect they didn’t mail it until the 4th — not because they needed the time, as it likely took no more than half an hour to copy/paste all the objections. I’m certain that the reason for this delay tactic was to ensure that I couldn’t do the “personal consultation” before I can file a motion to compel. By the time I finally get at least some real responses, it will be too late for me to file a motion to compel because 9/16 is the discovery deadline.


Over the last couple of weeks I wasted at least 30 hours on their BS. Considering that their main objective is to inflict as much stress as possible on me, they’re doing a FANTASTIC job.

Here’s my email to Mr. Kaminski:


Dear Mr. Kaminski,

After three 20 mile round trips to the post office, I finally received your discovery objections, allegedly mailed on 9/3, but not delivered until 9/7. You chose NOT to email your responses, presumably to waste another week and lots of my time and gasoline.

A brief summary of the issues:

First you told me that you needed an extension for the discovery responses, which I agreed to as long you got the court to move the discovery cutoff back accordingly.

Next, you did NOTHING.

Then you decided to send me a stipulation. However, in the stipulation you harped on “our” attempts to schedule the deposition, misrepresenting my cooperation and the fact that I NEVER objected to the depo date. I only objected to the location in Phoenix as I live about 60 miles from Kingman, your clients sued me in Kingman, then I sued your clients in Kingman and your clients chose to have the case removed to federal court in Phoenix.

There was absolutely NO reason to extend the discovery cutoff for the deposition as it was only a matter of Midland/MCM paying $250/day for me to drive to Las Vegas and I offered to make the 120 mile round trip(s) to Kingman with no charge to you.

You apparently abandoned the stipulation and decided to send me ONLY objections instead of responses to my discovery requests. Presumably, you just needed more time and that’s how you got it. Mr. Kaminski, you’re a GENIUS!

So please consider this my effort to resolve the matter through personal consultation prior to my motion to compel your clients’ responses.

Most sincerely,

Christine Baker

Scum sucking bottom feeding lawyers …