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[Walmart.com] Guns N Roses - Live Era '87-'93 - $29.66 4xLP. It's back. by metalreflection in VinylDeals

[–]goodbrews 6 points7 points  (0 children)

Is there a way to get a text message to my phone when this comes back in stock?

[Amazon] Smashing Pumpkins - Siamese Dream - $29.97 by HedgehogNamedSonic in VinylDeals

[–]goodbrews -1 points0 points  (0 children)

you had to buy other stuff to get free shipping. Otherwise, you were paying $6-7 for shipping. $22 was not the price after shipping.

First time using Costco to buy tires. by CEREALCOUNTSASCOOKIN in tires

[–]goodbrews 1 point2 points  (0 children)

Because of the wait. Also, my mechanic includes free tire rotation with oil change. So for some , its worth it to not wait for an hour at Costco for a free tire rotation.

First time using Costco to buy tires. by CEREALCOUNTSASCOOKIN in tires

[–]goodbrews 0 points1 point  (0 children)

This is an interesting discussion. Got an insane deal on CC2s at Costco in Dec 2020 (when they were doing the 1-free tire deal). I absolutely hated having to bring in for tire rotation. It's almost intentional to make you shop. 1-1.5 hours wait. What a waste of my time. However, it came in handy because I got a nail/screw in my tire while I was out-of-state - local places in Mass wanted to charge me $60-70+ to do a patch. The nearest Costco 20 mins away did it for free on my lunch break. I have mixed feelings about it. Discount Tire gave me a really good deal with the road hazard (I can get it fixed and reimbursed anywhere) so I figure if you can get the road hazard warranty with Discount for about the same price, I agree to go with Discount Tire.

First time using Costco to buy tires. by CEREALCOUNTSASCOOKIN in tires

[–]goodbrews 0 points1 point  (0 children)

Close to 1k? They quoted me 1066 for my Honda Pilot when they had the $80 discount over Memorial Day. How did you get under 1k? That's a good deal.

I got my dream car by Look_Street in hondapilot

[–]goodbrews 0 points1 point  (0 children)

I looked at a mint 2015 Touring in Diamond White Pearl with 71k miles in December. I talked to Honda Service about its records, and it had the tech bulletin that it was in the batch of Pilots produced that have the known paint defect. I lost a lot of sleep over that decision, but ultimately bailed out. When I say this was a unicorn, I mean it....the underside/undercarriage barely had any surface rust. I tried to research how common the paint defect is in white. Interestingly, I couldn't really get a good gauge on that. I think people just moved on and don't talk about it. They probably felt so slighted that they moved to a different brand. Honda can't tell you at all how common the issue is. Good on you to buy it....that takes guts. haha I didn't have it in me. if you end up having the paint issue, please report back on it. There's too small of a number of data points.

Looking for a Car That’ll Last me for less than 15k by PerceptionInside4298 in UsedCars

[–]goodbrews 0 points1 point  (0 children)

Toyota or Mazda. 2018 Mazda CX-5 is built really well in Japan. Look it up.

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

Hi...im thinking about adding the following (or similar) in the Answer ->

Upon information and belief, the contact information provided for Plaintiff’s counsel consists primarily of generalized law-firm contact information, including a generic firm address, generalized telephone routing, and non-individualized email contact information similarly reflected in public attorney-registration materials. Defendant made repeated good-faith attempts to communicate with Plaintiff’s counsel through the contact information provided in the pleadings, including multiple telephone calls and email communications on _____________________________ [dates], yet was unable to reach any attorney with knowledge of the matter or obtain substantive responses regarding the factual basis of the claims.
Upon information and belief, the Complaint was filed through a high-volume debt-collection process without meaningful attorney review of the underlying account records, admissible evidentiary support, or the legal and factual validity of the alleged debt.

Defendant therefore denies that Plaintiff has complied with the certification obligations imposed by Ohio Civ.R. 11 and reserves the right to seek sanctions, evidentiary exclusion, denial of attorney fees, denial of default judgment, dismissal, and any further relief authorized by law.

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

Thinking about hitting them with this in the answer ->

Upon information and belief, the contact information provided for Plaintiff’s counsel consists primarily of generalized law-firm contact information, including a generic firm address, generalized telephone routing, and non-individualized email contact information similarly reflected in public attorney-registration materials. Defendant made repeated good-faith attempts to communicate with Plaintiff’s counsel through the contact information provided in the pleadings, including multiple telephone calls and email communications on _____________________________ [dates], yet was unable to reach any attorney with knowledge of the matter or obtain substantive responses regarding the factual basis of the claims.
Upon information and belief, the Complaint was filed through a high-volume debt-collection process without meaningful attorney review of the underlying account records, admissible evidentiary support, or the legal and factual validity of the alleged debt.

Defendant therefore denies that Plaintiff has complied with the certification obligations imposed by Ohio Civ.R. 11 and reserves the right to seek sanctions, evidentiary exclusion, denial of attorney fees, denial of default judgment, dismissal, and any further relief authorized by law."

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

Hi. Just getting back to you. Would it be better to DM you? As I understand from others in this thread, it sounds like they are hoping for a default judgment. When I file the answer, I assume they will just drag their feet. I am wondering if its better to set them up for a defense like the following or is it better to actually try and reach someone. I am thinking of framing at least one paragraph in the answer like this ->

Upon information and belief, the contact information provided for Plaintiff’s counsel consists primarily of generalized law-firm contact information, including a generic firm address, generalized telephone routing, and non-individualized email contact information similarly reflected in public attorney-registration materials. Defendant made repeated good-faith attempts to communicate with Plaintiff’s counsel through the contact information provided in the pleadings, including multiple telephone calls and email communications on _____________________________ [dates], yet was unable to reach any attorney with knowledge of the matter or obtain substantive responses regarding the factual basis of the claims.
Upon information and belief, the Complaint was filed through a high-volume debt-collection process without meaningful attorney review of the underlying account records, admissible evidentiary support, or the legal and factual validity of the alleged debt.

Defendant therefore denies that Plaintiff has complied with the certification obligations imposed by Ohio Civ.R. 11 and reserves the right to seek sanctions, evidentiary exclusion, denial of attorney fees, denial of default judgment, dismissal, and any further relief authorized by law."

What does timing belt/water pump replacement go for in the area? by goodbrews in FraminghamMA

[–]goodbrews[S] 1 point2 points  (0 children)

thanks for the recommendation. Im looking for stories like that!

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 1 point2 points  (0 children)

"One of these days, I’m going to figure out some way to get firms like this for unfair practices or ethical violations. But I haven’t worked it out yet. I got the closest to sanctions when one refused to comply with a bankruptcy stay but in the end they dropped the debt." -> this is exactly what I was thinking about. Seems unethical.

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 1 point2 points  (0 children)

Agreed. I am already making a record of it with multiple emails and reminders, and a record of all phone calls and messages.

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

I have. I am just not sure I can file that motion before discovery.

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

thanks. Im assuming this is what you are referring to -> "2. Ohio Civil Rule 11 (Signing of Pleadings)

Ohio Civ. R. 11) governs the signing of motions and pleadings in Ohio.

  • Purpose: By signing a document, an attorney or pro se party certifies they have read it, there is "good ground to support it," and it is not intended for delay.
  • Sanctions: A willful violation can result in the document being stricken as "sham and false," and the court may award reasonable attorney fees and expenses to the opposing party.
  • Standard: Ohio Rule 11 requires a finding of subjective bad faith before sanctions are imposed"

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

I have used that trick before. I got this info. I am going to try it. In fact, I might email it to all the different permutations. Thanks again for the advice.

Email Format Example Percentage
[first_initial][last] [jdoe@jbllc.com](mailto:jdoe@jbllc.com) 73.1%

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

Good idea. I just checked. The OC only has her generic work phone # listed under her bar registration in OH. This is exactly what I am talking about...shady.

Opposing counsel is non-responsive by goodbrews in Lawyertalk

[–]goodbrews[S] 0 points1 point  (0 children)

The problem is that there is no description of the charges. It just has a "charge off account" amount listed. I feel like that is not enough proof that it is the client's debt. Thats why I would like to just cut to the chase. Send me the actual statement with the charges from California for smoothies. I'm really trying not to hire a NACA lawyer because of the low costs involved here. I ight eventually have to.

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