Alameda County Public Defender Objections Cheat Sheet. INTERROGATORIES A. Discovery objections cheat sheet california [Civ. E Discovery For Dummies Cheat Sheet dummies. As discussed in our article on American Litigation, discovery is a unique aspect of litigation in the United States that is a tool that often decides the outcome of the litigation. Jul 16, 2021 · While discovery is a standard part of litigation, attorneys do have the right to discovery objections in certain situations. This page provides a discovery objection cheat sheet for lawyers. DISCOVERY • Plaintiff may serve discovery questions - 10 days after service of complaint. This 10- page. 210(a)(3) and "each statement of compliance, each representation, and each objection in the response shall bear the same number. Utilize the right type in your case. This chart does not constitute or substitute for legal advice. You're free to object to a question of hearsay during a trial. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. "10 Often times they are used repetitively in response to multiple discovery requests. 90 days. DISCOVERY • Plaintiff may serve discovery questions - 10 days after service of complaint. (e) Making, without substantial justification, an unmeritorious objection to discovery. Common Objections Chart, page 1. '" quoting Matthew L. ] ] AGENCY #1-H-234-4567-89 Secretary, Department of the Navy, ] OFO Appeal #01234567 ] Agency. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. California Discovery Objection Calls for Legal Conclusion. And it is sanctionable to first object to a discovery request and, after the objections are overruled, respond that no such documents exist. and Federal law is beyond the scope of this chart, which includes common objections and a sampling of related supports in D. California Trial Objections Cheat Sheet. and Federal law is beyond the scope of this chart, which includes common objections and a sampling of related supports in D. E Discovery For Dummies Cheat Sheet dummies. These documents and information demonstrate that ENH raised its list prices . Kyle D. Problem #3: The Deposition “Objection--Vague, Ambiguous, Lack of Foundation, Assumes Facts not in Evidence, Incomplete Hypothetical and my client needs to talk to me. objections trial cheat sheet Bing Free PDF Links. Discovery Response Cheat Sheet: A. • Ruling. Below is a list of objections to evidence submitted in support of a pleading or motion, such as a motion for summary judgment. Code § 350; Brokopp v. 9 Question Is Too General. 1 Practice Tip: Leading Questions in Federal-Court Depositions §1:171 Objections to Foundation §1:172 Objections Relating to Relevancy §1:173 Objections Based on Privilege §1:174 Other Objections §1:175 Practice Tip: Speaking Objections and How to Stop Them VII. Then draft your discovery and demand answers that fairly and honestly answer the questions. Rule 193. (b) Errors and irregularities of any kind. Discovery objections cheat sheet california. Fong (Arizona 1965) 1 Ariz. :] EEOC 123-45-6789X Ive Ben Wronged, ] ] Complainant, ] ] vs. What facts or witnesses support your side. DISCOVERY OBJECTIONS CHEAT-SHEET Responding Party objects to this request as it calls for information that is not relevant, nor reasonably calculated to lead to the discovery of relevant or admissible evidence. “Asked and answered” is a standard objection during depositions when the deponent is repeatedly asked a question they have. Checklist of Common Objections Benchmark Institute. Counsel should not make objections or statements that suggest an answer to a witness. resolving, cheat sheet texas rules of evidence thorbloggt de, 2018 florida evidence code summary trial guide, depositions a cheat sheet the trial practice tips blog, free download here pdfsdocuments2 com , objections to testimony and documents at trial , denmon pearlman tampa bay attorneys 100s of 5 star reviews , discovery paralegal mentor,. , CCP § 2031. And in doing so, the court offered practitioners three important lessons. 4th 393, 401 (noting that RFA "differ fundamentally from other discovery devices" and that "[t]heir purpose is not the uncovering of information but the elimination of the need. California litigation cheat sheet by attorney steve. Discovery in family law. "] 2 "A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and. [3] OVERBREADTH, VAGUENESS, AMBIGUITY. The Discovery Code and interpreting case law provide for liberal discovery. However, the code makes it clear that the requirements in responding to Requests for Admissions are higher. Complete Your Responses to the Interrogatories. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. You use discovery to find out: What your spouse plans to say about an issue. California Civil Discovery KFC 1020. 3) Whatever negative facts that might come out in discovery can just be dealt with in a motion in limine. and Federal law. While the rules require objections to be specific to discovery requests, general objections as to attorney-client privilege and work product items may help protect you and the client. This chart is intended as a. In recent years, judges have been cracking down and making it harder for attorneys to object. Studying the rules will prepare you to make. Problem #3: The Deposition “Objection--Vague, Ambiguous, Lack of Foundation, Assumes Facts not in Evidence, Incomplete Hypothetical and my client needs to talk to me. 4th 703, 719 stated: “if respondents had desired to do so, they could have deposed [the expert] in an attempt. My first admonition to you is always chide your adversary for interrupting you mid-question. Code §765. 240 – Requirements For Objections. 30(b)(6), where the deponent objects. This PDF doc contains objections in court cheat sheet. Here's how yours know. Discovery and discovery requests are proportional if:. Written Discovery There are generally four possible responses to a written discovery request, and there is a. The party submitting the interrogatories may move for an order under Rule 37(a) with respect to any objection to or other failure to answer an interrogatory. that is not relevant, nor reasonably calculated to lead to the discovery of relevant or admissible evidence. To learn about litigation in general, see Litigation. 3d 1142, 2005 WL 1175 922 (9th Cir. Responding party objects that the request seeks documents already in plaintiff’s possession custody or control. Objection: Lawyer-client privilege. objections, or incomplete responses, simplifying the discovery process. By way of example, the following objections or comments by counsel generally can be viewed as suggesting an answer to a. A complete list of all evidentiary objections and related supports in D. com www. Code of Civil Procedure section 2020. Jarvey, Boilerplate Discovery Objections: How They Are Used, Why They Are Wrong, and What We Can Do About Them, 61 Drake L. • Object (e. The question has a double meaning, capable of being understood in more than one way. This page provides a cheat sheet for discovery objections for lawyers. By way of example, the following objections or comments by counsel generally can be viewed as suggesting an answer to a. You are in the middle of a particularly pointed, well-phrased question when you hear "Objection, outside the scope of direct. That legitimate concern triggers an objection. General Objections. Basic Evidence Rules and Objections California. Pratt & Whitney,. ) or work product; Relevance; Defective deposition notice; Defects in the oath or affirmation administered; Abusive questioning, or other misconduct by a part, counsel, or deposition officer;. 5 Responding to Objections. 3d 841, 860. TIMELY RESPOND; PRESUMPTION OF . April 25th, 2018 - Objections Cheat Sheet Objection HEARSAY Rule 401 Witness is testifying about a document not yet entered. G674 California Deposition and Discovery Practice KFC 1020. California discovery objections cheat sheet. Not Applicable Refer to attached list, chart, table or timeline. 38 CAL. E Discovery For Dummies Cheat Sheet dummies. In an important but easily-overlooked decision, the Court of Appeal for the First District upheld an award of discovery sanctions based on objections to the practice of propounding interrogatories about a party's responses to previous interrogatories. (See, e. Los Angeles County Superior Court, No. While the Supreme Court still considered the issue on appeal, it cautioned counsel that the far better practice is to repeat and renew the objections during the trial itself. objections to such discovery requests. When a natural person is being deposed, whether or not that person is a party to the case, you must conduct the deposition either a) within 75 miles of the deponent's residence, or b) within 150 miles of the deponent's residence and in the forum county. The process can be very difficult, for all parties involved. The following is a cheat sheet of some of the most common legal objections: Purpose: To prevent the witness from being unduly influenced. and Federal law is beyond the scope of this chart, which includes common objections and a sampling of related supports in D. This PDF doc contains objections in court cheat sheet. Sample written objections to evidence submitted in support of or in opposition to a summary judgment or summary adjudication motion in an unlimited civil case in California superior court. Subsection (b) (1) (A) states that the request must “describe with reasonable particularity each item or category of items to be inspected. A complete list of all evidentiary objections and related supports in D. In litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. 3 It explains the basic facts of the case, the legal violations that are alleged to have occurred, and requests a specific type of relief from the court (usually money). 9 Question Is Too General. Evidentiary Challenges to Documents for Trial Hahn amp Hessen. My first admonition to you is always chide your adversary for interrupting you mid-question. 010 to 2036. those objections, and use that list to assist you in saving time on interrogatories. and Federal law. Sep 13, 2019 · Recall that the Code of Civil Procedure requires either a statement that the party will comply, a representation that the party lacks the ability to comply, or an objection to the particular demand. 21 Service of summons Fed. This matter is hereby certified for trial and plaintiff(s) is directed to file a note ofissue within. This article takes a look at some of the most common of those. Pointers for Responding to Discovery Requests, 19 Sedona Conf. Objections not raised in a timely manner are waived, or given up. Interrogatory responses containing unverified factual responses and objections only trigger the 45-day motion to compel deadline when . Checklist of. RULES United States Courts. Discovery is the formal process parties use to a case gather information and evidence from each other in preparation for trial. Rule 3. Every request for discovery, response or objection thereto made by a party . " Relevance: "Objection, your honor. This page provides a cheat sheet for discovery objections for lawyers. discovery, when that party/counsel has shotgunned objections to all inquiries (reasonable or not) by the. Below is a list of objections to evidence submitted in support of a pleading or motion, such as a motion for summary judgment. Creating a discovery plan. The primary rule governing requests for production is CR 34. , attorney-client, physician-patient, privacy, Fifth Amendment, etc. PRIVILEGE; SUPPLEMENTATION AND AMENDMENT; FAILURE TO. California discovery objections cheat sheet. COMMONLY USED OBJECTIONS: FRE FORM OF THE QUESTION Rule 403—Cumulative / Asked and Answered The court may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting. 9 Question Is Too General. Back to Main Page / Back to List of Rules. 4 Objecting to Evidence. This 10- page. And in doing so, the court offered practitioners three important lessons. This page provides a discovery objection cheat sheet for lawyers. Types of Objections §1:170 Objections to Form §1:170. This 10- page. July 2018. A Motion to Quash challenges that improper service. HEARSAY OBJECTIONS AND EXCEPTIONS By Simon H. This chart is intended as a. Objections are organized topically. Hearsay questions are perfectly legitimate ways of obtaining information and pursuing that. 1 9-3 In Federal court, an attorney filing documents must • change the names of minor children to initials, • limit financial account numbers and Social Security numbers to. DISCOVERY OBJECTIONS CHEAT-SHEET. See CR 33(b). request must state whether anything is being withheld on the basis of the objection. Apr 7, 2020 · The following objections are among those that are: Privilege (i. Proof of Service must be filed within 60 days of filing of the original complaint. E Discovery For Dummies Cheat Sheet dummies. Going through discovery is a bit like navigating a minefield. A defendant in the civil action may seek discovery from a bankruptcy trust. and Federal law is beyond the scope of this chart, which includes common objections and a sampling of related supports in D. Discovery Objections Cheat Sheet California. OnLAW CP94550 Web access for one user. Common Objections Chart, page 1. Florida Trial Objections Cheat Sheet Discovery Paralegal Mentor May 1st, 2018 - Discovery Tips Tricks and Best Practices www paralegalmentor com ©2010. Directly to the right of the available objections are the supporting. Responding party objects that the request seeks documents already in plaintiff’s possession custody or control. What facts or witnesses support their side. 2 jul 2021. This chart is intended as a. CCP § 2025. The term of the amendments that. Rules Of Evidence Cheat Sheet California cyteen de. 010 et. Elsewhere on this website, we talk about the importance of forcing defendants to provide meaningful answers to interrogatories, requests for the production of documents, and other discovery responses and requests. California Civil Litigation and Discovery KFC 995. or Objection: Request No. 300; Korea Data . CCP § 2025. Please see our separate article. Los Angeles County Superior Court, No. deciding how or whether to use the information in this chart. Peeples, 734 S. This PDF doc contains objections in court cheat sheet. Ford Motor Co. Possible Gray Areas In some situations, an objection may be proper but in other situations the same exception may not be proper. April 25th, 2018 - Objections Cheat Sheet Objection HEARSAY Rule 401 Witness is testifying about a document not yet entered. 110] ] [See also CCP § 583. Discovery closes before trial: 30 days before trial - or 15 days before arbitration. OBJECTIONS: See Standard Objections, above. Here are a handful of those templated objections that could be used during an interrogatory which may be cause for documents to be protected from disclosure. Discovery Response Cheat Sheet: A. 1987) (orig. 270(a)) Notice to state: • nature of deposition • date, time, place • deponent’s rights and duties; and penalties for disobedience • subpoena, witness fee and mileage on or before deposition (§ 2025. (2002) 104 Cal. For legal professionals. Carry the laminated Checklist of Objections in your trial notebook. A Motion to Quash challenges that improper service. Objections-- Objections to the form of a question or privileged information must be stated at the time of the deposition or they are waived. Common Objections Chart, page 1. 210(a)(3) and “each statement of compliance, each representation, and each objection in the response shall bear the same number. Discovery objections california cheat sheet. Oct 24, 2020 — discovery objections cheat sheet california. :] EEOC 123-45-6789X Ive Ben Wronged, ] ] Complainant, ] ] vs. will be included in the production. For more detailed information, including local rules, see the California Superior Court SmartRules Interrogatories and Response to Interrogatorie s Guides and Codes, Courts and Forms. Responding party objects that the request seeks documents already in plaintiff’s possession custody or control. Trial objections - procedures strategies and the 18 most common courtroom objections. and Federal law. Florida Trial Objections Cheat Sheet priorityforce. Superior Court (1974) 42 Cal. 00 Qty: Overview Table of. 24 ago 2017. The attorney for the responding party shall sign any responses that contain an objection. “Asked and answered” is a standard objection during depositions when the deponent is repeatedly asked a question they have. Court of Appeals of California, Second Appellate District, Division Three. 38 CAL. Objections not raised in a timely manner are waived, or given up. California Civil. A single objection may be more effective than several objections. Book A Consultation Contact Us Today For A Divorce Case Evaluation. and CEB, California Civil Discovery. This is the time when you take over control of the UD case. Interrogatory responses containing unverified factual responses and objections only trigger the 45-day motion to compel deadline when . CAALA members may cut and-paste the objections listed in this article into their discovery responses by downloading the article from the CAALA Web site at http://www. Just filing it adds a minimum of 18 days to your time of possession, costs your landlord to oppose it, disappoints the landlord and his lawyer, and sets the stage for the next phases. Discovery objections cheat sheet california [Civ. Seems Obama is between a rock and a firing squad my personal feelings about a death sentence is we should not excute. E Discovery For Dummies Cheat Sheet dummies. Objections - 21226 44766 Document - Free download as PDF File (. Superior Court (1974) 42 Cal. 38 CAL. Of course, the question about these types of appeals is likely to raise objections from defense lawyers on the basis of "factual question for the Trier of facts," "legal question that a layman cannot answer," "requires a legal conclusion," or "calls for an expert opinion. The following are examples of such objections: a) hearsay b) relevance c) opinion d) lacks foundation 5. dry-list of general objections for withholding documents but. Utilize the right type in your case. deciding how or whether to use the information in this chart. Southern District) 4. In litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. Basic Evidence Rules and Objections California. Mar 9, 2011 · (b) Each answer shall: (1) Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as reasonably and clearly qualified by the responding party. 010 et. Effective December 1, 2015, subsection (b) (2) (C) was amended to require that "an objection to a. Character evidence is evidence that tends to suggest a party's conduct occurred in conformity with their character. Guide: Civil Procedure Before Trial (TRG 2010) ¶8:721 et seq. What facts or witnesses support your side. 210; CALIFORNIA CODE OF CIVIL PROCEDURE § 1141. Civil trials no longer are to be conducted in the dark. •Guidelines for Professional Conduct, Fla. Calls for Information Regarding Consulting Expert. DeArmas and W. watch demon slayer online free reddit
Any agreement by Moody's to produce documents is made without waiver of any objections, and is not intended to constitute a representation that any such documents exist, but only that Moody's will produce what documents do exist, are in its possession, custody and. . California discovery objections cheat sheet
Plaintiff objects to each instruction, definition, document request, and interrogatory to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. Free Consulting: (800) 553-8082. Seems Obama is between a rock and a firing squad my personal feelings about a death sentence is we should not excute. Bloom Sugarman, LLP. We also have established a growing list of partner colleges that guarantee LawShelf . A single objection may be more effective than several objections. When a natural person is being deposed, whether or not that person is a party to the case, you must conduct the deposition either a) within 75 miles of the deponent's residence, or b) within 150 miles of the deponent's residence and in the forum county. For legal professionals. ” See Fed. pdf document contains the legal authorities for dozens of common evidentiary objections in an easy-to-read chart. A request for production, as the name suggests, is a request for another party to produce something, usually copies of documents. Mock Trial Rules of Evidence short form. 400 or collections per 3. Objections-- Objections to the form of a question or privileged information must be stated at the time of the deposition or they are waived. Discovery Response Cheat Sheet: A. The person you need information or answers from is required to respond to your request. An objection is often missed when the interrogatory in question contains subparts or is compound, conjunctive, or disjunctive. Then draft your discovery and demand answers that fairly and honestly answer the questions. 1 See, e. or Objection: Request No. Common Objections Chart, page 1. Responding party objects to this request as it seeks documents that are not within defendants’. Below are common objections to consider in drafting your responses. 1) Overly broad. An effective objection is designed to keep inadmissible testimony, or testimony harmful to your case, from being admitted. The attorney assures opposing counsel that the answers will be provided shortly and asks. , §§ 1985. See CR 33(b). , 2021 WL 287874, at *1 nn. Plaintiff objects to each instruction, definition, document request, and interrogatory to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. When a natural person is being deposed, whether or not that person is a party to the case, you must conduct the deposition either a) within 75 miles of the deponent's residence, or b) within 150 miles of the deponent's residence and in the forum county. :] EEOC 123-45-6789X Ive Ben Wronged, ] ] Complainant, ] ] vs. Objections are organized topically. e-Discovery For Dummies. And in doing so, the court offered practitioners three important lessons. The article may be found in the Advocate Magazine section under Advocate Article Archive Library. 01 with respect to any objection to or other failure to answer an interrogatory. 310 follows the federal. This chart does not constitute. request must state whether anything is being withheld on the basis of the objection. Info will not help Trier of fact Insufficient foundation to qualify expert Not beyond experience of . Thank you! According to the National Court Repo. Objections not raised in a timely manner are waived, or given up. Checklist of. CRC 3. An effective objection is designed to keep inadmissible testimony, or testimony harmful to your case, from being admitted. The discovery objections cheat sheet is a helpful tool for attorneys to use when preparing for depositions and trials. I am requesting access to records in possession or control of the [insert. 3d 1142, 2005 WL 1175 922 (9th Cir. As a litigator in California, you are responsible for lot of discovery. Immediately after the top caption, your response must include the name of the requesting party, the responding party, and the set number of the request. This table sets out the most common objections, as well as exceptions to those objections. The following are examples of such objections: a) hearsay b) relevance c) opinion d) lacks foundation 5. Lexis Advance. ] ] AGENCY #1-H-234-4567-89 Secretary, Department of the Navy, ] OFO Appeal #01234567 ] Agency. That legitimate concern triggers an objection. and Federal law is beyond the scope of this chart, which includes common objections and a sampling of related supports in D. April 25th, 2018 - Objections Cheat Sheet Objection HEARSAY Rule 401 Witness is testifying about a document not yet entered. See CR 33(b). “Asked and answered” is a standard objection during depositions when the deponent is repeatedly asked a question they have. Read Depo Defense Cheat Sheet. (b) If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection shall be set forth clearly in the response. See King v. Rule 32 (c) (2) requires that an objection be stated "concisely in a nonargumentative and nonsuggestive manner. discovery, when that party/counsel has shotgunned objections to all inquiries (reasonable or not) by the. 9 These objections are taglines, completely "devoid of any individualized factual analysis. and Federal law. Often, questions are vague because they contain an unclear reference. Common Objections Chart, page 1. California Civil Discovery Practice KFC 1020. DeArmas and W. Litigators know the familiar song and dance of responding to discovery requests—the response starts off with a list of general objections . Objections to Scope of 30(b)(6) Notices for Depositions Objections to the scope of a deposition notice shall be raised by timely serving those objections upon the opposing party in advance of the deposition, not by filing a motion for protective order seeking anticipatory review before the deposition. These documents and information demonstrate that ENH raised its list prices . If the objections above are not raised in a pre-trial motions, they may still be raised when the expert witness is. Discovery objections must be specific and geared to inform the court and counsel as to what the potential problem is so it can be corrected. State objections simply and clearly. If the discovery request calls for an application of facts to the law, the objection will typically be overruled. You do not need to repeat the text of the question, but your responses must be in the same order as the requests, and each response should be. 1) Overly broad. 29 ago 2018. are protected from discovery and disclosure by the attorney work product doctrine and Code of Civil Procedure §2018. The primary rule governing requests for production is CR 34. The article may be found in the Advocate Magazine section under Advocate Article Archive Library. 310 follows the federal. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. Common Objections Chart, page 1. This page provides a cheat sheet for discovery objections for lawyers. California Trial Objections DOC San Francisco Personal. Beyond Scope of Discovery Cal. Sheets v. You should only use this form as a guide and. The guide is designed as a "cheat sheet" you can add to your trial notebook or bring to hearings and depositions. A single objection may be more effective than several objections. California discovery objections cheat sheet. :] EEOC. Southern District) 4. Trial objections cheat sheet california. Discovery in family law. 26 mar 2018. (b) the objection of the witness to the question or questions. Because getting pinned down with an actual response, "Admit," or "Deny," carries significant risk, most responses are far more lengthy. ) or work product; Relevance; Defective deposition notice; Defects in the oath or affirmation administered; Abusive questioning, or other misconduct by a part, counsel, or deposition officer;. Government Code §§ 6253(d) & 6255(b) require that any response to this. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. Possible Gray Areas In some situations, an objection may be proper but in other situations the same exception may not be proper. The California Code of Civil Procedure sets forth strict deadlines for many types of discovery motions. The court’s opinion in Berroteran v. Objections 13 Common Objections c ymcdn com. (b) If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection shall be set forth clearly in the response. Discovery objections california cheat sheet. Mar 30, 2020 · Rule 34 of the Federal Rules of Civil Procedure provides for discovery and inspection of documents and things in the course of developing a case for trial. Every request for discovery, response or objection thereto made by a party . "Objection, hearsay!") You must state the basis of your objection. California discovery objections cheat sheet. at 119, 734 P. 401 402 403 Classroom Law. part of a general list of generic objections preceding any responses to specific . Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. The rule and expectation is that your objections be precise. California discovery objections cheat sheet In litigation, the written discovery is typically composed of (1) production requests, (2) admission requests and (3) interrogators. 34 (b) (1) (A). It also includes requests for production of documents. This court of objections statement decision california? Evans made on appeal for objections cheat sheet right to statement of obtaining witness statements and defenses thereby. 030 subdivision (a) states, "[a] writing that reflects an attorney's impressions, conclusions, opinion, or legal research or theories is not discoverable under any circumstances. That said, objecting isn’t quite as easy as it used to be. 020 and. 9 Question Is Too General. Every request for discovery, response or objection thereto made by a party . . amouranth uncensored pussy, sexcelebrity, suzume no tojimari full movie online, max mara near me, section 3 reinforcement particles in solution answer key, score mariners game, propane forge harbor freight, afghanistan xxx, mobile homes for rent cheap, tween girl age, szyprn, anitta nudes co8rr