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Law Educator, Esq.
Law Educator, Esq., Attorney
Category: Legal
Satisfied Customers: 118253
Experience:  JA Mentor -Attorney Labor/employment, corporate, sports law, admiralty/maritime and civil rights law
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PAUL. Good evening. New queries for you on Exhibits! I

Customer Question


Good evening.

New queries for you on Exhibits!

I know "tina"already file i think,because i have msg.of happiness-tone in her voice. i love it.
and i was busy working with so many today and at the university for my own classes etc.
before i call her i have a question on her exhibit(s) i know workin at many law firms;
was always shown,taught to only attach the most significant naturally.and she has over
like dozens!(strong newly discover evidence)but i think she will be fine with just 1-10 or
is this too much? i.e. "gang rape-proof from dr. own notation to judge,validating such"
that state knew,but withheld.

2.Exhibit demonstrating child was"lost in the system"but yet was told by caseworker the complete antithesis;stating child is home with"Dad"living well,in school no risk at all paul.

3.the mug shot news article front page!(whereas;a man prior to gang rape,in foster care also harm her,sex abuse,and beat her up.(the article)is also enumerating,the events and
how state worker(s)were called etc.and the father took her to hospital .
and naturally"State"clear mom of the allegations that kept her child out of the home for years!"(showing it was finally marked as OVERTURNED;unfounded,and also the Appeal
excerpt,citing" in 07 to investigate,or the entire appeal"as it also say how state is taking way too long,and/"the "long delay"has affected,the parental right,of the mother and is delaying,"the child right"to her own parent.

is this enough?

the A.P.B. bulletin!
(remember, this?)mom learn about it NOT from state,but supermarket or a store near her
how sad is that, during same time CPS just swore weeks prior in court,child was fine paul

OR should she just throw in everything? i think not,because,your saying this is just the actual General Complaint,albeit; "Amended-But still" and lawyers i use to work at 12 firms
ALL use to say."1 to a few strong pieces"if warranted,some lawyers only put one who i use to help as a paralegal daily,hence i think she not put in all of it,i hope she did not!
but calling her after i speak to you thanks paul!

Submitted: 4 years ago.
Category: Legal
Expert:  Law Educator, Esq. replied 4 years ago.
Thank you for your new question.

Quite honestly, if she does not have to attach any exhibits to her complaint the better. It is generally always best to hold off on exhibits until the discovery phase. That is a problem many pro se litigants have, they want to attach all of their proof to the complaint because they think it helps and all it does is give the opponent chance to object or come up with evidence to counter her evidence. So in discovery she would request them to produce documents and they would request her to produce her documents and she would produce some that are required under the Rule 16 disclosures and the rest she would wait until she receives a request for production. If they never request them, she would introduce them in trial. Ultimately, she will want to introduce all of those exhibits.

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Customer: replied 4 years ago.

ok i got it paul!


and (btw)

why then do a attorney for the state,usually (in the MTD) to have it dismiss at the early stages,it always seems,the case(s)we review here,for years the lawyer,when he file his state opposition,"to avoid having to resond"to the facts presented by the injure pary,why the state lawyer always attach a doc or two?(i.e. appeal decision,to other things paul)just curious,thank you.night.

i will be accepted tonight before bed,or morning! thx again so much.




Expert:  Law Educator, Esq. replied 4 years ago.
Thank you for your response.

A motion, unlike a petition or complaint, requires supporting evidence and documentation which is done through exhibits and also a memorandum in support of the motion explaining their grounds and case law and statutory support. Under the federal law a petition is a general notice pleading, meaning as long as it hits all of the highlights of the allegations and states the causes of action that is all required for submission of a valid complaint.
Customer: replied 4 years ago.

so helpful.

evening paul.

thank you.I just like to triple check it all.

and update:


i verify even though 2 days late from mon.she finally got it file!

(she know that,she has not serve yet,the copy of her complaint until the court

summon(s) are issued)


she was going to serve the cps caseworker,and supervisor,etc. their copy without it.i told her not to.and final note on this,she did NOT add her very strong supportive evidence(exhibits)so thank you for that paul.





Expert:  Law Educator, Esq. replied 4 years ago.
Thank you for the update.

You are correct, she needs to serve them the subpoena with the copy of the complaint to have proper service. I suggest she use a professional process server as they know how to properly make service, especially when suing a state agency.