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  1. Thanks, I made an appointment withThe Law Office of Jerry Jarzombek, PLLC in Fort Worth. I've read good reviews about him. Has anyone used them before?
  2. Here is a TX case I found for a pro se. "The Court finds that GBS and Shytles were debt collectors under the FDCPA at the time they filed suit against McNeill in the Dallas County Court at Law because of their regular consumer debt collection activities between January 28, 2002 and January 28, 2004. The Court further finds that GBS and Shytles violated the FDCPA when they filed the lawsuit against McNeill in the Dallas County Court at Law, rather than in Harris Count. As a result of GBS and Shytles v
  3. @BV80No I've never been to Bowie County. @texasrocker I'm just been trying to find whatever I can to dismiss or drop the case. I found that them filing in the wrong venue violates several statues and wanted to use it to help my cause. The only reason I would want to sue would to get them to go away. I wasn't saying I was wanting to sue for mental anguish, thats just what I read about the violation. I was more focused the part were they can be found in violation without knowingly to have done it, and if they are found to have knowingly done it then they would be found liable for other damages
  4. DTPA doesn't mention a bona fide error defense like the FDCPA or TDCA do.
  5. Would it be worth asking them in a letter to the JDB lawyer to drop his suit due to the DTPA violation?
  6. Do I mention the all of the laws and codes in my motion to transfer venue?
  7. (23) filing suit founded upon a written contractual obligation of and signed by the defendant to pay money arising out of or based on a consumer transaction for goods, services, loans, or extensions of credit intended primarily for personal, family, household, or agricultural use in any county other than in the county in which the defendant resides at the time of the commencement of the action or in the county in which the defendant in fact signed the contract; provided, however, that a violation of this subsection shall not occur where it is shown by the person filing such suit that the perso
  8. @texasrocker So I have found a few options to pursue. I can file a motion to dismiss under TCRP91a. Effect of Venue and Personal Jurisdiction -this rule is not an exception to the pleading requirements of Rules 86 and 120a, but a party does not, by filing a motion to dismiss pursuant to this rule or obtaining a ruling on it, waive a special appearance or a motion to transfer venue. By filing a motion to dismiss, a party submits to the court's jurisdiction only in proceedings on the motion and is bound by the court's ruling, including an award of attorney fees and costs against the party.
  9. Yes it does state I have 50 days to answer their discovery which I was aware of. What I wasn't sure of is of how it will effect me if I send the JDB discovery with my answer, or my request for their discovery prior to asking the court for transfer or dismissal based on wrong venue. I have read were it is required to submit the request for transfer or dismissal with my answer to the court, or that it is not required and I can file any time before my court date after answering. Not sure which is correct. If I can file them separately is it better to get it all submitted at the same time with
  10. @texasrocker When should I send my answer for the discovery items they requested from me? I found a form where you provided the items with answers to the long list of questions for the requests for disclosure, production, admissions, and first set of interrogatories. The forum was also for PRA, so I am assuming it is the correct one to use. Also, they asking for verification under oath and have it notarized. I am reIuctant to sign it with my signature in fear they may falsify documents to use against me like putting it on a contract they say I signed with them or something. Should that even b
  11. @texasrocker I have read a few forms where you have helped some people with this JDB. I ordered the book on Amazon you recommended and also have the DEFENDANT'S ORIGINAL ANSWER, PLEA TO THE JURISDICTION AND SPECIAL EXCEPTIONS you instructed to copy and insert the Facts section with exact language to deliver to the court. You sent a PM to those you helped in the other forms for the first set of discovery. Your help with the discoveries and any other help would be greatly appreciated. Here is the info for my case. 1. Who is the named plaintiff in the suit? Portfolio Recover