I send a long Production of Documents list - including a request for all telephonic recordings that relate to my loan - (this is key evidence, because the voice recordings will contradict what the bank's written documents say - I have their "loan file" docs).
The bank's attorney claims that I must request those calls with "appropriate specificity". How can I be more specific than asking for "recordings of all phone calls that relate to my loan"?
Also, what does the bank's requested "protective order" imply? The bank claims that the recordings are "confidential and private", and will be produced only if I sign a protective order. What does that mean? How carefully should I scrutinize the protective order?
Last question: My trial is in March of 2014; when is last day to enter evidence?