What should I do to ensure that I can oppose the SJ motion and to have a bench trial on the factual issues in contention?

I suggest you immediately make a motion (1) to vacate the order on the grounds that you did oppose the motion; (2) and/or, in the alternative,...

I am no longer within the timeframe to file a lien, but can I sue him in Small Claims Court and then file a lien?

You should sue him in small claims court. You could get information and forms on line. If you win, you will get a judgment that enables you to...

Selected as the best answer

What is next for me ? What does it really mean ? Should I file for dismissal or what?

By denying the plaintiff summary judgment, the court is saying that their case is not ironclad and that there are questions of fact. If you need...

How would someone be able to sue me and recover anything if I have no assets and do not earn a salary?

They can sue you and if successful, get a judgment against you that will typically last 10 or more years, subject to further renewal. Whether they...

Can a pro se litigant be represented at a trial by another non-attorney pro se advocate?

No. Other than representing yourself, only a licensed lawyer can represent someone else in court.

What are the differences between 'Petition for Rehearing', 'Application for Further Appellate Review', and 'Petition for Cert '?

To meaningfully answer, I need to know if this is a criminal or civil matter, and what court you are talking about. Is it a state court or federal...