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If your attorney is missing deadlines and not objecting to their refusal to answer interrogatories and depositions, then this is arguably malpractice and grounds to pursue your attorney for improperly handling the case and seek damages from him. Additionally, it is grounds to dismiss him and hire on a new attorney, which is what it sounds like is needed here.
The issue with the change of beneficiary form, if they prove it was a legitimate change form, even if they failed to file it or provide notice to you, would arguably still be enforceable, which is likely why your attorney is not seeking to raise this issue with the court.
Yes, summary judgment is standard procedure and in order to defeat their summary judgment, you have to prove that there are material issues of fact that are still in dispute and that you have legal basis still for a claim based on those disputed material facts. Your attorney though, from what you are stating, does not sound like he is working diligently to pursue this for you as he is legally bound to do and as such you might want to consider pursuing him for malpractice and seeking a new attorney to pick up the case and to do so before you fire him outright, you need to take the case documents showing what he has or has not done to another local attorney to review and agree to take on the case. Once you have an attorney agreeing to take on the case, that is when you terminate this one and if what he did causes you to lose your case then you sue him for malpractice and seek your damages.
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