which motion to file
I'm being sued by an insurance co, I filed a summary judgment because the statue of limitation was past (so I thought, but I guess they made it under the wire by 2 days. ) However, the judge told the plaintiff his complaint was sloppy and he didn't even state a valid claim so he needs to refile it by 1/28/08. I then need to file another answer. Discovery is already complete and the evidence is nothing buy hearsay, irrelevent, stuff. I don't think they really have a case. My question is what type of an answer do I file? Can I file a Motion to strike and Dismiss in one pleading as an answer to the 2nd complaint? Or do I ask for another summary judgment? I know I need/should hire an attorney, but I'm a single mom working 2 jobs just to make ends meet - I have no extra money at all - filing fees along are strapping me. My last Motion for Summary Judgement I filed even the judge told me I did an excellent job and she was impressed. However, now I have to do it all over again! Any and all advise would be welcome.