CIVIL DISPUTE CONSULTANTS LLC DISCOVERY PACKAGE APPLICATION

Instructions: Please provide information requested below and e-mail the completed form to jeff@civildisputeconsultants.com. We will respond after review of your information.

Your Name: _______________________     Your address:_______________________

Your telephone number: __________________   Cellphone number: ______________

Your e-mail address: ___________________________

Name of Company (or companies) or persons involved in dispute:________________

_____________________________________________________________________

Address(es) of companies or persons involved in dispute:________________________

_____________________________________________________________________

Telephone number(s) of companies or persons involved in dispute:_________________

E-mail addresses of companies or persons involved in dispute:___________________

____________________________________________________________________

_____________________________________________________________________

Jurisdiction (location) of dispute: (city and state): ______________________________

Has a lawsuit been filed and if so, where/court?:  ______________________________

Nature of dispute: (e.g. sale of goods, services provided, money claimed owed and reason(s)) ____________________________________________________________:

Amount of money involved in dispute: ______________________________________

Are you or your company claiming that money is owed? :_______________________

Status of case (e.g. already in discovery phase; set for mediation (date); set for trial (date); depositions scheduled and if so, for what date(s): _____________________

___________________________________________________________________

Have discovery requests been made? If so, what, when, and by whom ___________

____________________________________________________________________

Have any responses to the discovery been provided? If so, when and nature of responses (e.g. answers and/or objections): _______________________________

__________________________________________________________________

Discovery tools you are requesting: (state “yes” or “no” next to each):

Interrogatories: _______   Request for Production: _______

Request for Admissions: _______    Other (please specify) ___________________

Signature of applicant: ________________________    Date signed: _____________

(BELOW FOR CIVIL DISPUTE CONSULTANTS LLC USE ONLY)

Copy of current version of lawsuit:  _______           Copy of Answer to lawsuit _______

Current discovery requests: ______________________________________________

Documents requested from applicant: ______________________________________

Date requested and means (e.g. e-mail): ____________________________________

Mailing address: Civil Dispute Consultants LLC, 324 South Beverly Drive, No. 1101,        Beverly Hills, California 90212. ALL RIGHTS RESERVED.

February 5, 2026

Civil Dispute Consultants LLC (CDC) is adding case-specific discovery tools to its inventory of services and as part of its educational programs. The tools include requests for production, requests for admissions, interrogatories, and questions to ask in a deposition of the opposing side’s designated representative (a/k/a “30(b)(6) deposition). The discovery tools are case-specific and seek facts, documents, and information  pertinent to the specific case and on the basis that no “standard” or ‘form” discovery is required by the jurisdiction where the case is pending.

Several states have what is called “form’ or “standard” discovery tools for certain types of cases which tools have been approved by a state Bar or court. These are typically for cases involving motor vehicle-incident-related claims; medical malpractice claims; and matrimonial case claims. Other states may have standard discovery tools for other types of cases including construction-defect claims and “general negligence” claims.

CDC’s principal spent 37 years developing case-specific discovery over the course of his civil litigation practice which involved cases in over 30 states and including cases in both state and Federal courts, and also for certain types of administrative law cases. His resume/curriculum vitae is available by e-mail request to jeff@civildisputeconsultants.com.  The development of these case-specific tools lead to numerous settlements, successful mediations, and positive results at trials and in appeals.

CDC’s case-specific discovery tools are priced both individually (e.g. for only a Request for Production) or as a complete set (interrogatories, Request for Production, and Request for Admissions). Preparation of topic areas and issue-based deposition questions will be made available separately.

All charges will be on a flat invoice basis (not an hourly fee basis) after CDC reviews the case file including any lawsuit, exhibits, prior discovery, and motions. A determination will then be made as to the charges for work in developing specific discovery tools based on the amount of projected work involved.

All discovery tools are for informational and educational purposes only and do not constitute legal advice.

Forms will shortly be made available for case outline, status, and ordering discovery tools. Inquiries may be sent to: jeff@civildisputeconsultants.com.

Civil Dispute Consultants LLC

December 16, 2025

Civil Dispute Consultants (CDC) is preparing to launch its initial programs for 2026. These virtual courses include sessions dealing with understanding the mechanics of collection practices, managing the various stages of civil (monetary) debt disputes, and factors affecting debt resolution, including potential or actual (in-progress) litigation.

A separate course will introduce the basics of civil litigation, including a breakdown of the various stages of a lawsuit from the initial filing to the conclusion of the dispute. You will learn the structure and purpose of the lawsuit (the Complaint); types of responses which are available; discovery (oral and written); what are called “dispositive motions” (such as motions for summary judgment); Mediation and arbitration; trial; post-trial filings; and appeals.

The course is scheduled to take approximately ninety (90) minutes and will include outlines to be provided to each participant. Time will be allotted for “Q&A” at the conclusion of the program.

The cost of the course is $195.00, which can be paid in parts so long as the full payment is made 5 calendar days before the date of the course presentation. Two sessions of the course will be offered live on the same day at different times to make the course conveniently available to participants in different time zones.

A course outline and application will be posted shortly. Inquiries may be made to Jeff Barnes, jeff@civildisputeconsultants.com.

Civil Dispute Consultants LLC

November 23, 2025

First, we here at Civil Dispute Consultants LLC (CDC) wish everyone a Happy Thanksgiving.

We have had a number of inquiries from people across the US who have been served with either a “demand letter” or lawsuit involving a claimed debt and/or demand for payment, including questions as to what the function of a lawsuit is and the steps in the process. Although there is a lot of “substance” online as to potential defenses to a lawsuit, there appears to be almost no information as to what a lawsuit seeks to accomplish; the manner by which it is done; and the function of the various stages of a lawsuit (the Complaint or Statement of Claim; the types of responses available; discovery; what are called “dispositive” motions); Mediation, and trial.

Our informational sessions (which are conducted virtually online and involve both instruction and “question and answer” periods) are scheduled to begin on December 1, 2025, with explanations as to what each phase involves, what each phase seeks to accomplish, and the mechanics of each phase. The sessions are general and for informational purposes only, and do not and are not to be construed as providing legal advice: Our aim is to educate non-lawyers as to the mechanics of a demand or lawsuit.

Inquiries may be addressed to jeff@civildisputeconsultants.com.

Civil Dispute Consultants LLC

November 7, 2025

The prevailing wisdom among businesspersons, homeowners, and the self-employed is that a tsunami of  claims are about to be asserted arising out of civil disputes. This includes demand letters, default notices, and forms of collection activity such as lawsuits.

There are literally tens of thousands of people involved in civil disputes of one form or another who do not know how the civil claims process works or what to expect when a demand is made upon them..We at Civil Dispute Consultants LLC educate and provide information to those involved in a civil dispute so that they understand the process, the forms of dispute resolution, and procedures of the different processes which include informal attempts to settle, Mediation, and procedures associated with litigation.

All sessions are conducted by our Managing Member who has a Master of Science degree in Education; taught students at the elementary, junior, and senior high school levels in both public and private schools, and to Master’s and Ph.D candidates.

We are available for private consultation sessions which are scheduled by appointment. The one-hour sessions consist of 15-20 minutes of instruction followed by 40-45 minutes of “Q&A” to answer specific questions.

The litigation method is the slowest and most costly, and with the highest level of uncertainty as to the ultimate outcome. As a result, more and more people are seeking alternative forms of civil dispute resolution, which includes informal settlement communications and Mediation. These methods are designed to lead to a resolution with finality and without the uncertainty, cost, and duration of litigation.

The problem is that although there is a lot of substance on the internet, there is a  dearth of information on procedure and what someone who has had a claim or demand made against them.should expect. At Civil Dispute Consultants LLC, we will explain how the systems work, the events involved, and the mechanics of mediation and litigation. We will have a call-in number and e-mail address to send questions and to arrange for consultation sessions with the goal of educating persons involved in a claim as to the claims process including methods of resolution without litigation being instituted or continued.

The information to be provided will be generic and applicable to all types of civil disputes. We will not provide any legal advice, which is best handled by an attorney representing someone who is the subject of a claim.

Civil Dispute Consultants, LLC

We are seeing a recent ramping up foreclosures by investment banks and servicers on loans originated in the early-to-mid 2000s after a somewhat lengthy period of inactivity. Many of these are old Countrywide and WaMu loans which, allegedly, have been transferred to securitization trusts involving Deutsche Bank, JP Morgan Chase, US Bank, HSBC Bank, and others which were involved heavily in the securitization of mortgage loans beginning in 2000.

Litigation on the issues never fully resolved many of the issues surrounding standing to foreclose, the viability of assignments, questionable endorsements, and setoff issues. Thus, these issues, depending on the jurisdiction, are still undecided and thus ripe for assertion.

We are also seeing an increase in “zombie” loan claims as well as claims made by different entities as to who allegedly succeeded to the interest in a Note and/or mortgage instrument, and suspect that these types of cases will continue to increase given the present state of the economy including what appears to be a “tightening up” by the banks in approving mortgage applications. With less loans being originated, the “banks” are apparently searching their books to seek to foreclose on old loans which they had not acted upon for years in order to boost their balance sheets and perception of assets..

Jeff Barnes, Esq.

Historically, trials in eviction cases were conducted by the court without a jury. The argument by the “bank” and servicer attorneys was that an eviction is the product of a foreclosure, and the loan documents contained a waiver of jury trial provision which, they argued, applied to an eviction arising out of a foreclosure. As eviction actions are governed by statute and the Colorado statutory framework adopts jury trials in specific situations, the issue came before the Supreme Court of Colorado.

On October 21, 2024, the Colorado Supreme Court issued it opinion in Mercy Housing Management Inc. v. Bermudez, 2024 CO 68, which reversed the County Court’s denial of Bermudez’ request for a jury trial in an eviction (FED) case. The opinion details the history of the right to a jury trial in specific actions including actions seeking possession and recovery of specific real property.

The Housing Group and the County Court took the position that there was a distinction between actions to recover specific real property versus those for possession of real property in terms of whether a jury trial was proper. The CO Supreme Court found no such distinction, and reiterated the right to a jury trial in eviction actions.

Mr. Barnes is currently defending an eviction case in Colorado which was to be scheduled for trial in November of 2024. The case arises out of two CRCP 120(d) challenges to two non-judicial foreclosures filed by Deutsche Bank as Trustee of a 2006 securitized mortgage loan trust. The first matter was decided adverse to the client and is currently the subject of an appeal. Deutsche Bank had removed the client’s CRCP 120(d) challenge to the nonjudicial foreclosure to Federal Court, which was ultimately remanded and appealed after an adverse decision dismissing the client’s CRCP120(d) Complaint which sought to nullify an Order Authorizing Sale entered in the 120 proceeding. While the matter was pending in Federal Court, Deutsche Bank filed a second CRCP 120 nonjudicial foreclosure case notwithstanding that the first 120(d) challenge remained pending..

After remand, Deutsche Bank filed an eviction action and requested that it be set for trial. The client demanded a jury trial, which was done before the Mercy Housing opinion was issued. A pretrial conference was held just days after the opinion issued, and the County Court was presented with the issue of setting a jury trial. Deutsche Bank’s counsel moved to withdraw from the case shortly thereafter and has not had any new counsel enter an appearance in the case.

The County Court Judge has given Deutsche Bank a limited period of time to retain new counsel and enter an appearance, otherwise the eviction case will be dismissed. Meanwhile, the appeal of the first foreclosure decision remains pending, as does the appeal of the second adverse decision, both of which concern the same loan, the same real property, the same borrower, and the same essential legal issues relating to whether Deutsche Bank ever acquired any enforceable interest in the loan. The Colorado Court of Appeals denied the client’s motion to consolidate the two appeals, both of which are in the briefing stage.

Jeff Barnes, Esq. for ForeclosureDefenseNationwide.com

December 12, 2023

In a 53-page decision following a 3-day trial, a South Carolina Master in Equity has denied the remedy of foreclosure to U.S. Bank as a claimed securitization trustee. The litigation was ongoing for 12 years, and the Plaintiff took inconsistent position that the Note existed, then claimed it was lost, later claiming it was found. The ruling details the myriad failures of the Plaintiff as to lack of evidence, evidence which was not credible, and a litany of misconduct on the part of the Plaintiff throughout the history of the case.

Jeff Barnes, Esq. represented the homeowner for practically the entire 12-year history of the case and tried the case with local South Carolina counsel William “Bill” Sloan, Esq.

Jeff Barnes, Esq., Foreclosure Defense Nationwide

November 20, 2023

A private investigator who performs detailed mortgage loan audits has located the most incredible admission in a PSA::

(b) Purchaser acknowledges, understands, and agrees that Sellers have constructive or actual knowledge that fraud, misrepresentations, or omissions occurred in connection with the origination or modification of some or all of the Mortgage Loans and Sellers may have undertaken investigations or other steps with respect to some or all of such instances of fraud, misrepresentation, or omission. Purchase acknowledges, understands, and agrees that Sellers will not identify the Mortgage Loans subject to Seller investigations, nor will Sellers provide any information about such Seller investigations. Purchaser expressly assumes all risks arising from fraud, misrepresentation, or omission in connection with the origination or modification of te Mortgage Loans.

So the sellers of the loans to the securitizations admit to engaging in fraud and misrepresentation, will not give any details as to this, and the buyer buys admittedly fraudulent loans and takes all responsibility for them.

Jeff Barnes, Esq., www.ForeclosureDefenseNationwide.com

January 18, 2023

A New Mexico District Judge has today denied Fannie Mae’s motion to reinstate a case which was dismissed for lack of prosecution. The homeowner is represented by Jeff Barnes, Esq., who previously vacated a judgment in favor of FNMA. Although FNMA claimed that it was going to ask the Court to reinstate the case, the Court declined to do so, ruling that FNMA had not demonstrated excusable neglect or good cause for its ignoring the case for an extended period of time without prosecuting it.

FNMA claimed that the delay in prosecution was due to “pending receipt of a client executed Affidavit attesting to the accuracy of the amounts Plaintiff will seek in Judgment.”

New Mexico law permits the dismissal of an action where 180 days pass with no activity. Here, the Court did not dismiss the action for lack of prosecution until 394 days had passed with no activity, which was the period beginning from the date that the Final Judgment was vacated (that being May 10, 2021) to the date that the Court issued its Notice of impending dismissal for lack of prosecution (which was on June 8, 2022).

New Mexico case law requires a party to demonstrate “exceptional circumstances” to support a request for reinstatement of a case after a dismissal for lack of prosecution. Mr. Barnes cited to a case from the Supreme Court of New Mexico which affirmed the denial of a request for reinstatement where there was no significant activity for 1.5 years.

The homeowner was and is represented by Jeff Barnes, Esq. together with local New Mexico counsel Ana Garner, Esq.

Jeff Barnes, Esq., www.ForeclosureDefenseNationwide.com