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I have a question I have a case I filed a response to a request for admissions in a civil case the attorney has responded with this "Motion to Deem Plaintiff’s Requests for Admissions Deemed Admitted and for Sanctions" what are my options to respond?

Lawyer's Assistant: Since laws vary from place to place, what state is this in?

California

Lawyer's Assistant: Has anything been filed or reported?

Yes the interrogatories general and special as well as the Request for admissions. I responded to all of them and since I dropped them off a few days ago the attorney filed and sent me "Motion to Deem Plaintiff’s Requests for Admissions Deemed Admitted and for Sanctions" what response can I send

Submitted: 1 month ago.Category: Legal
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Answered in 8 minutes by:
3/7/2018
Lawyer: INFOLAWYER, Attorney replied 1 month ago
INFOLAWYER
INFOLAWYER, Attorney
Category: Legal
Satisfied Customers: 60,954
Experience: Licensed attorney helping individuals and businesses
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If you responded to the request, I see no basis to deem them admitted where you admitted or denied their claims. Court will normally deny the motion. Please let me know if the reply is acceptable by responding “yes” or “acceptable”
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Customer reply replied 1 month ago
On some of them I stated I do not admit or deny the allegations on the grounds that my response may violate the privacy of a third party until the time that the violation of privacy be lifted.
Lawyer: INFOLAWYER, Attorney replied 1 month ago
Ok. The court may direct a response at worse over your objections.Please let me know if the reply is acceptable by responding “yes” or “acceptable”
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Customer reply replied 1 month ago
Do I need to file anything like a protective order or do I actually need to respond by law to defend myself. My response was 1 day after the agreed to time with the attorney. I walked it in myself and got a letter with a signature from the attorney myself.
Customer reply replied 1 month ago
That is what he is stating. We had the case management conference, but are waiting for the case settlement meeting. Am I ok since I was a day late.
Lawyer: INFOLAWYER, Attorney replied 1 month ago
I would do both. I would respond and seek a protective order! One day delay is fine.Please let me know if the reply is acceptable by responding “yes” or “acceptable”
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Customer reply replied 1 month ago
I do not understand he could have filed a motion to compel with the court, but instead he filed "Motion to Deem Plaintiff’s Requests for Admissions Deemed Admitted and for Sanctions" What document is needed to respond to the "Motion to Deem Plaintiff’s Requests for Admissions Deemed Admitted and for Sanctions" is there another motion or a specific response.
Lawyer: INFOLAWYER, Attorney replied 1 month ago
He is seeking to be agressove and not compel responses. The relief is extreme and a court will usually not grant it since you acted in good faith.Please let me know if the reply is acceptable by responding “yes” or “acceptable”
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Customer reply replied 1 month ago
he was very aggressive when I stated I would come to his office to drop the documents off and demanded me to show up before he closed or would file a motion to compel immediately. He seems like he a collections attorney because he races through all the steps, pushes his way through and files motions for default judgments one day after he can and demands me to come or else. I have no money or job and I am doing this alone. He seems like he is used to pushing his weight around and trying to scare people. So all I have to do to respond is to file a protective order request and use what type of response. A motion or is there a specific response.
Lawyer: INFOLAWYER, Attorney replied 1 month ago
I would oppose the motion on ground you responded timely and in good faith and if a protective order is needed to allow that as relief!
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Customer reply replied 1 month ago
Do I need to respond to each
MEMORANDUM OF POINTS AND AUTHORITIES
I. FACTUAL BACKGROUND.
or can it be just a one page response requesting a protective order.
Do I actually have to respond line by line to each point of authorities.
Customer reply replied 1 month ago
The attorney is not the lead attorney on the case. Can I ask the judge to make sure I deal with the lead attorney in the case on the Protective order or is there a way to have the judge order the secondary attorney at the same law firm not be harassing me and only deal with lead attorney. Is there a document for that or add that into the Protective order?
Lawyer: INFOLAWYER, Attorney replied 1 month ago
Not line by line but should address and oppose the arguments. You cannot require lead attorney deal with matter in papers or otherwise as the firm has the right to delegate which is standard practice. Protective order is something you would be seeking by your own motion supported by reasons why you believe some information should not be produced. Keep in mind courts generally require full disclosure without limits and may at most issue a confidentiality order.Please let me know if the reply is acceptable by responding “yes” or “acceptable”
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Lawyer: INFOLAWYER, Attorney replied 1 month ago
Awaiting your reply, thank you!
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