This project would be good for any attorney with 0 – 2 years experience – or more. A modicum of experience with civil discovery is all that is needed.
The case you will be working on is a breach of contract case. I am not a party to the case; I am a third-party witness. There was a jury trial and the case has been reduced to a money judgment. An Abstract of Judgement has been recorded in the county records by the Plaintiff/Judgment Creditor. The only issue left is collection on the judgement.
In purported furtherance of the Judgement Creditor’s efforts to collect on the judgment, he has served to me a DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND PRODUCTION OF DOCUMENTS AND THINGS. The subpoena asked for production of 61 separate categories of documents at the deposition.
I timely wrote and sent to the attorney for the Judgment Creditor valid objections to the production of certain of the requested documents. There was then a series of letters exchanged in which we disagreed as to the validity of my objections.
The Judgement Creditor filed a Motion to Compel production of the documents.
I need an attorney to write a letter to Judgment Creditor in an attempt to get him to take the motion off calendar. If that does not work, I will need to file opposition to the Motion to Compel.
The hearing is set for May 29 at the Stanley Mosk Courthouse (downtown LA), but probably the hearing can be attended by phone or Zoom.
Everything I need done can be done remotely by phone and email. If filing opposition papers is necessary, to start with I will write out for you all of the facts and the law that I already know applies to the facts. I have done the legal research already. You will develop what I give you into a pleading that you are proud of and file it and appear at the hearing. I estimate that you will spend maybe 14 hours on this if the hearing can be attended by phone or zoom.
If this interests you please respond by email. Pay offered is $70/hour - or what we negotiate. The case number is 19STCV20062. You can see a list of all the documents filed in the case on the court's website for free or if you want I can email you selected documents and/or portions of documents so you can evaluate the matter quickly.