I am being sued to foreclose on my home. I presented a motion for summary judgment based on lack of standing. The judge asked both parties to submit a “findings of facts and conclusions of law” before the trial. Is that document the one the judge will end up signing (for the winning party?). If so, my problem is that many of the facts might change during the trial. I presented 3 issues regarding standing, and the first two might be easily fixable, for instance by bringing original or certified documents. Only my third issue, improper transfer (which cannot be made retroactive) is unfixable. Thus, some of the findings of facts that I can write before the trial might be outdated after the trial. Then, my question is: how do I write a findings of fact without knowing the facts in advance? Or will this document will be later modified after trial to adjust to the new facts?
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