I lost the lawsuit. This hearing for reconsideration came about at my ex-parte motion hearing for a stay of judgment while on appeal. At that hearing the judge asked me why I wanted to appeal and I explained that I had subpoened the credit card company witness but she never showed up and I objected to her declaration in lieu. He found for the credit card company anyway so I had grounds for an appeal. He said he wanted to take it under submission because he might just vacate the judgment but a few days later I got notice from the clerk that the judge had changed my stay motion to a motion for reconsideration and set a new hearing date. Thank you.
Based on what you've said, you can probably expect to lose. I think you are wasting your time.
This is AVVO, a place for users to obtain general legal information to general legal questions. I am glad to help you in any way I can, within those limits. I wish to make clear I am only communicating with you for the sole purpose of exchanging such general information, and nothing more. It is not legal advice, which I can not provide because among other reasons I know few of the necessary details of your situation. I do not purport to represent you in any way, shape or form. Of course, if you would like to seek out my services, and if you are a NY resident, I will probably not put up very much resistance but representation would still necessitate a signed retainer agreement between yourself and I. Thank you.