Since I had been trying to get Home Affordable Modification since March, 2009, and nothing much happened until I began seriously working on Discovery, I feel that my trial period was a result of Wells Fargo wanting to avoid Discovery.
In fact, Wells Fargo was supposed to respond to my Requests for Admissions:
But WF didn't, instead WF put me in the trial period, only its lawyers refused to vacate the hearing set for October 19, on their motion for summary judgment.
As soon as WF lawyers got a stay on discovery, they had WF cancel my trial period. A WF rep told me that on October 20 their lawyers had told them to cancel my trial period.
Some of my requests are stated wrong, because I have a bit of brain injury and I got confused about what I wanted admitted. (if they are denied in 30 days, then they are "conclusively" deemed admitted.)
Admissions 45-69 have to do with me trying to pay off my mortgage in 2005 and Wells Fargo not accepting my offer, preferring instead to set another auction date. I like number 66 a lot...
Curious what you think about a counterclaim... and have you used one?