NeedHelpNebraska

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  1. In Nebraska the SOL is 4 yrs. I am being sued and the SOL has run out. I responded to the summons, then responded to the collectors request of admissions, and sent my own requests back to them...which took along time to get answered. From there the SOL is up on the debt, and I have not heard anything from the collector for 6 months. Case is still active and has not been dismissed. Can I have the case dismissed on time barred? Or can I have it dismissed on lack of prosecution? I am open to Ideas. Thanks
  2. I am Security Credit and they missed the date they were suppose to return the discovery questions back to me. They missed it to the point they asked the court for an extention, and missed that date as well. Do I have anything going in my favor? Thanks.
  3. I just finished updating my discovery answers. If there are any issues that some one sees, please let me know asap, as I am submitting them this afternoon. Thanks for all the help, and I am starting on my return discovery to the plaintiff.
  4. I have edited my answers to post 44. I really need help...just want to get this buttoned up. I know what needs to be said, just unsure how to say it correctly. Thanks
  5. Again, please look this over, if I am getting to bold with my objections, please someone reel me in. I left 6 blank...I have no documents...is it ok to put that? Thanks, in advance. Production of Documents: 1. Produce all documents furnished to you by the Plaintiff or the Plaintiff's Assignor. Response: Defendant has no such documents either because they have been lost, destroyed, were never created, or in the Defendant’s possession in the first place. 2. Produce all documents furnished to you by the Plaintiff or to the Plaintiff's Assignor. Response: Defendant has no such documents either because they have been lost, destroyed, were never created, or in the Defendant’s possession in the first place. 3. Produce all records showing any payments made on this account, Response: Defendant has no such documents either because they have been lost, destroyed, were never created, or in the Defendant’s possession in the first place. 4. Produce the three most recent tax returns filed by the defendant. Response: Objection. Plaintiff requests personal and private information that is irrelevant and unlikely to lead to admissible evidence. 5. Produce the three most recent payroll stubs from the defendant's employment. Response: Objection. Plaintiff requests personal and private information that is irrelevant and unlikely to lead to admissible evidence. 6. Produce all documents identified in your answers to interrogatories. Response: None at this time, but the Defendant reserves the right to amend per the Rules of Procedure. 7. Produce every document, writing, paper or letter which you intend to utilize as a basis or ground for any defense in this action or which expect to offer into evidence upon the trial on this action. Response: The Defendant demands strict proof, and the burden of proof is on the Plaintiff to prove standing to sue.
  6. Interrogatories: 1. If you deny any of the foregoing requests for admission, please specify in detail the reasons for the denial. Answer: Defendant is not legally liable to the Plaintiff as to each and every allegation. 2. State your full name, address, telephone number, date of birth, and Social Security number or work permit number. Answer: This information is, upon information and belief, already in Plaintiff's possession. The term 'work permit number" is unknown to Defendant. 3. State fully, completely, and at length the factual basis for denying that the Plaintiff's assignee performed all of it obligations under the contract. Answer: OBJECTION Beyond defendant's scope of knowledge. Ownership of the account has not been established as fact. Defendant has no clue as to the business practices of junk debt buyers 4. State fully, completely and at length the factual basis foe denying that the Defendant defaulted under the agreement by failing to provide the agreement upon payments. Answer: Objection, The request is beyond the scope of the Defendant’s knowledge and calls for legal conclusion. Defendant has denied entering into an agreement with Plaintiff. 5. State fully, completely and at length the factual basis for denying that the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus pre-judgment interest at the statutory rate of 12% per annum, from October 2011 to the date of judgment. Answer: Objection, no complete record of the alleged debt has been included, therefore defendant cannot make an informed response. 6. State fully, completely, and at length the factual basis for denying that demand for the above stated amount was made by the plaintiff to the defendant. Answer: Denied, as the burden of proof is on the Plaintiff to prove that the Defendant owes said amount. 7. State fully, completely and at length that the factual basis for denying that monthly statements were mailed to the defendant at the address provided by the defendant. Answer: Objection, Calls for a conclusion related to the mailing practices of a third party, which is beyond the scope of knowledge of Defendant 8. State fully, completely and at length the factual basis for denying that the defendant accepted said statements without making objections to. Answer: Objection, no proof of delivery of the alleged statements has been included, therefore Defendant can not make an informed response. 9. State fully, completely and at length any facts upon which the defendant will rely on in defense of this action. Answer: Defendant is not legally liable to the Plaintiff. 10. State the name, occupation, business address and telephone number, residence address and telephone number of witness you expect to call to rely upon in the trial of this action, together with a summary of the matters to be testified about within the knowledge of each witness. Answer: Defendant has no witnesses at this time. 11. State the name, occupation, business address and telephone number of each person having knowledge of any facts which are the subject of the above entitled action together with a summary of facts known by each person. Answer: Defendant has no said persons at this time. 12. State the name, occupation, professional credentials, business address and telephone number of each expert you expect to call or rely upon in trial of this action, together with a summary of the matters to be testified about within the knowledge of each such expert. Answer: Defendant has no said experts at this time. 13. State the names and addresses of all persons from whom the defendant, or anyone acting on the defendant's behalf, has obtained statements that in any way relate to the facts or claims which are the subject of the above-entitled action. Answer: Objection, no proof of delivery the alleged statements has been included, therefore Defendant cannot make an informed response. 14. For each statement contained in your Answer to the preceding Interrogatory, state: a. For each statement was taken: b. The name and address of the persons who took the statement; c. the location where the statement was taken; d. The names and addresses of all persons present at the time the statement was obtained or who otherwise witnessed the taking of the statement; e. the form of the statement obtained (e.g, written, recorded, etc.); f. The names and addresses of the custodians on the statement. Answer: Do I put my name and address 15. If you have not admitted any one of the Plaintiff's Request for Admissions served upon you this same date, then, with respect to each such Request not fully admitted, state all the facts known to you, directly or indirectly, which you contend to be the basis for the denial or refusal to admit each such Request. Answer: Defendant is not legally liable to the Plaintiff as to each and every allegation. 16. Are you currently employed? If so: a. What is the name, address and telephone number of your employer? b. What is your net ("take-home") pay, per say period? Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims. 17. Do you own or rent your residence? a. if you rent, please state: 1. How much is rent? 2. What is the name and address of your landlord? b. If you own (or are purchasing) your residence, please state: 1. Your monthly payment. 2. the value or your home. 3. how much equity do you have in your home? 4. The name and address of the mortgage holder or deed holder (the entity to whom you send your payments). Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims. 18. Do you have an active back account? If so, please state: a. The name and mailing address of the bank or banks. b. Checking or savings account? c. The names of all people listed as owners of the bank account. Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims. 19. What is your marital Status? Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims. 20. Do you have any minor Children (under 19 Years of age) Living with you? a. If yes, please state the ages of each child. Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims. 21. Do you won any vehicles? For each vehicle please state: a. Year, make, and model of vehicle. b. Monthly payments, if any. c. Approximate Value of Vehicle. Answer: Objection: The interrogatory cannot lead to the discovery of evidence which would be material to the Plaintiff's claims.
  7. can i say the "Plaintiff is calling for a legal conclusion, and therefore is improper" or should I just leave it as denied?
  8. Admissions: 1. That the following documents are attached hereto: Exhibit a: A true and correct copy of Customer Agreement Exhibit B: A true and Correct copy of Billing Statements March 09 to January Exhibit C: A true and correct copy of Bill of Sale Exhibit D: A true and correct copy of Application signed by you. Response: Denied 2. That the defendant entered into an agreement that is currently held by the Plaintiff by applying for and obtaining a Credit card bearing account number xxxx-xxxx-xxxx-xxxx(exhibit A) Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation. 3. That the defendant used said credit card, making periodic payments on the account until on or about 9/**/2009. Response: Denied 4. That by using the credit card, the Defendant agreed to be bound by the terms of the agreement. Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation. 5. That the account which is the subject of this action was validly sold and assigned to the Plaintiff. Response: OBJECTION The request is beyond the scope of the defendant's knowledge and calls for a legal conclusion. Assignment constitutes standing to sue, which is the burden of the plaintiff to prove, not defendant. 6. That the Plaintiff's assignee performed all of its obligations under the Agreement. Response: Denied 7. That the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus prejudgment interest at the statutory rate of 12% per annum, from Oct 2011 to date judgment is entered herein. Response: Denied. 8. That demand for the above stated amounts has been made by the Plaintiff to the Defendant. Response: Denied 9. That the monthly statements were mailed to the Defendant at the address provided by the Defendant. Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation. 10. That the Defendant accepted said statements without making objection thereto. Response: Denied 11. That the Defendant defaulted by failing to make payments in the amount set forth on said statements. Response: The Defendant is without sufficient knowledge to form an opinion and therefore denies, in it's entirety, the allegation. 12. That, after due demand, the Defendant remains indebted to the Plaintiff in the amount of $xx,xxx plus pre-judgment interest t the statutory rate of 12% per annum, from Oct 2011 to the date of judgment in entered herein. Response: Denied. 13. That there are no facts upon which the Defendant relies as a basis for any defense in this action. Response: Denied 14. That there are no documents, writings, letter, records or papers of any sort which the Defendant intends to utilize as evidence of or a basis for a defense in this action. Response: Not at this time, but the Defendant reserves the right to amend per the Rules of Procedure. 15. That the material allegations contained in the Plaintiff complaint are true. Response: Denied
  9. I am not real sure how to say my objections, I feel I am repeating my self alot here. Please look this over and offer any advice. Thanks. 1. That the following documents are attached hereto: Exhibit a: A true and correct copy of Customer Agreement Exhibit B: A true and Correct copy of Billing Statements March 09 to January Exhibit C: A true and correct copy of Bill of Sale Exhibit D: A true and correct copy of Application sighed by you. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s evidence. 2. That the defendant entered into an agreement that is currently held by the Plaintiff by applying for and obtaining a Credit card bearing account number xxxx-xxxx-xxxx-xxxx(exhibit A) Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s evidence, as the Plaintiff is making an unsupported claim of ownership. 3. That the defendant used said credit card, making periodic payments on the account until on or about 9/**/2009. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s evidence, as the Plaintiff’s date is in dispute as it may establish that the Statue of Limitations has expired. 4. That by using the credit card, the Defendant agreed to be bound by the terms of the agreement. Response: Objection, the Plaintiff has not cited any relevant statute proving that this is law in Nebraska 5. That the account which is the subject of this action was validly sold and assigned to the Plaintiff. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim, as the Plaintiff is making an unsupported claim of ownership. 6. That the Plaintiff's assignee performed all of its obligations under the Agreement. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is calling for a legal conclusion, and therefore is improper. 7. That the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus prejudgement interest at the statutory rate of 12% per annum, from Oct 2011 to date judgement is entered herein. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is calling for a legal conclusion, and therefore is improper. 8. That demand for the above stated amounts has been make by the Plaintiff to the Defendant. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is making an unsupported claim. 9. That the monthly statements were mailed to the Defendant at the address provided by the Defendant. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. 10. That the Defendant accepted said statements without making objection thereto. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. 11. That the Defendant defaulted by failing to make payments in the amount set forth on said statements. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Default is not defined herein, not were any documents attached that would allow the Defendant to make an informed decision. Default is either a matter to be determined by the alleged agreement or by the trier of fact. 12. That, after due demand, the Defendant remains indebted to the Plaintiff in the amount of $xx,xxx plus pre-judgment interest t the statutory rate of 12% per annum, from Oct 2011 to the date of judgment in entered herein. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim. Plaintiff is calling for a legal conclusion, and therefore is improper. 13. That there are no facts upon which the Defendant relies as a basis for any defense in this action. Response: Deny 14. That there are no documents, writings, letter, records or papers of any sort which the Defendant intends to utilize as evidence of or a basis for a defense in this action. Response: Not at this time, but the Defendant reserves the right to amend per the Rules of Procedure. 15. That the material allegations contained in the Plaintiff complaint are true. Response: Objection, the Defendant has no way to verify and validate the Plaintiff’s claim.
  10. They have included copies of statements from the credit card that show payments, but it does not show who made them. It just says automatic payment, thank you. Clearly I am headed toward the proof of standing....correct.
  11. Do I have to give my financial info....banking, cars, house and so on.....That is more after the judgement right. The more I read the more I understand how this is working. Just want to make sure my answers are correct, and not to allow any evidence the JDB has in to court on my own account.
  12. I am typing up answers today....is one word object Ok, or do I need to support my objections? Thanks
  13. I sorta feel really defeated after reading all of these pages. All help is greatly appreciated.
  14. Last page. The Plaintiff herein requests the defendants to produce the following documentation and things for inspection and reproduction, within thirty day of the date of service, in accordance with rules 26 and 34 of the Nebraska Discovery for Civil Cases. 1. Document or Documents means writing, drawing, graphs, charts, photographs, correspondence, facsimiles, memorandum, written messages, handwritten or typed notes, evaluations, contracts, diaries, expense records, internal correspondence or memorandum, minutes, resolutions, summaries, statements, drafts of any of the above documents, and any other data compilations from which any information can be obtained or can be translated, if necessary, by the defendant into reasonable usable form. 2. the documents and things should be produced as they are kept in the ordinary course of the defendant's business or within the record keeping system regularly used by the defendant. 3. The party upon whom the request is served shall serve written response with in thirty days after service of the request, unless the request is objected to, in which event the reasons for the objection shall be stated. Requests: 1. Produce all documents furnished to you by the Plaintiff or the Plaintiff's Assignor. response: 2. Produce all documents furnished to you by the Plaintiff or to the Plaintiff's Assignor. Response: (must be important....its in there twice.) 3. Produce all records showing any payments made on this account, response: 4. Produce the three most recent tax returns filed by the defendant. response: 5. Produce the three most recent payroll stubs from the defendant's employment. response: (I am self employed...and on paper I do not make a lot of money...how do I show that?) 6. Produce all documents identified in your answers to interrogatories. response: 7. Produce every document, writing, paper or letter which you intend to utilize as a basis or ground for any defense in this action or which expect to offer into evidence upon the trial on this action. response.
  15. How much info should I give them if anything? I feel like I am cutting my self of at the knees if I answer any of these questions...and making the case for the other side. 1. If you deny any of the foregoing requests for admission, please specify in detail the reasons for the denial. Answer: 2 State your full name, address, telephone number, date of birth, and Social Security number or work permit number. Answer: 3. State fully, completely, and at length the factual basis for denying that the Plaintiff's assignee performed all of it obligations under the contract. Answer: 4. State fully, completely and at length the factual basis foe denying that the Defendant defaulted under the agreement by failing to provide the agreement upon payments. Answer: 5. State fully, completely and at length the factual basis for denying that the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus pre-judgement interest at the statutory rate of 12% per annum, from October 2011 to th date of judgement. Answer: 6. State fully, completely, and at length the factual basis for denying that demand for the above stated amount was made by the plaintiff to the defendant. Answer: 7. State fully, completely and at length that the factual basis for denying that monthly statements were mailed to the defendant at the address provided by the defendant. Answer: 8. State fully, completely and at length the factual basis for denying that the defendant accepted said statements without making objections to. Answer: 9. State fully, completely and at length any facts upon which the defendant will rely on in defense of this action. Answer: 10. State the name, occupation, business address and telephone number, residence address and telephone number of witness you expect to call to rely upon in the trial of this action, together with a summary of the matters to be testified about within the knowledge of each witness. Answer. 11. State the name, occupation, business address and telephone number of each person having knowledge of any facts which are the subject of the above entitled action together with a summary of facts known by each person. Answer. 12. State the name, occupation, professional credentials, business address and telephone number of each expert you expect to call or rely upon in trial of this action, together with a summary of the matters to be testified about within the knowledge of each such expert. Answer: 13. State the names and addresses of all persons from whom the defendant, or anyone acting on the defendant's behalf, has obtained statements that in any way relate to the facts or claims which are the subject of the above-entitied action. Answer: 14. For each statement contained in your Answer to the preceding Interrogatory, state: a. For each statement was taken: b. The name and address of the persons who took the statement; c. the location where the statement was taken; d. The names and addresses of all persons present at the time the statement was obtained or who otherwise witnessed the taking of the statement; e. the form of the statement obtained (e.g, written, recorded, etc.); f. The names and addresses of the custodians on the statement. Answer: 15. If you have not admitted any one of the Plaintiff's Request for Admissions served upon you this same date, then, with respect to each such Request not fully admitted, state all the facts known to you, directly or indirectly, which you contend to be the basis for the denial or refusal to admit each such Request. Answer: 16. Are you currently employed? If so: a. What is the name, address and telephone number of your employer? b. What is your net ("take-home") pay, per say period? Answer: 17. Do you own or rent your residence? a. if you rent, please state: 1. How much is rent? 2. What is the name and address of your landlord? b. If you own (or are purchasing) your residence, please state: 1. Your monthly payment. 2. the value or your home. 3. how much equity do you have in your home? 4. The name and address of the mortgage holder or deed holder (the entity to whom you send your payments). Answer: 18. Do you have an active back account? If so, please state: a. The name and mailing address of the bank or banks. b. Checking or savings account? c. The names of all people listed as owners of the bank account. Answer: 19. What is your marital Status? Answer? 20. Do you have any minor Children (under 19 Years of age) Living with you? a. If yes, please state the ages of each child. Answer 21. Do you won any vehicles? For each vehicle please state: a. Year, make, and model of vehicle. b. Monthly payments, if any. c. Approximate Value of Vehicle. Answer:
  16. Here are the discovery questions....please help me so I do not hang my self, as these are set up to lock their case. Thanks Please admit or deny the following allegations. 1. That the following documents are attached hereto: Exhibit a: A true and correct copy of Customer Agreement Exhibit B: A true and Correct copy of Billing Statements March 09 to January Exhibit C: A true and correct copy of Bill of Sale Exhibit D: A true and correct copy of Application sighed by you. (these papers are included...how do I respond) Response: 2. That the defendant entered into an agreement that is currently held by the Plaintiff by applying for and obtaining a Credit card bearing account number xxxx-xxxx-xxxx-xxxx(exhibit A) Response: 3. That the defendant used said credit card, making periodic payments on the account until on or about 9/**/2009. Response: 4. That by using the credit card, the Defendant agreed to be bound by the terms of the agreement. Response: 5. That the account which is the subject of this action was validly sold and assigned to the Plaintiff. Response: 6. That the Plaintiff's assignee performed all of its obligations under the Agreement. Response: 7. That the Defendant is indebted to the Plaintiff in the sum of $xx,xxx plus prejudgement interest at the statutory rate of 12% per annum, from Oct 2011 to date judgement is entered herein. Response: 8. That the above stated amounts has been make by the Plaintiff to the defendant. Response: 9. That the monthly statements were mailed to the Defendant at the addess provided by the Defendant. Response: 10. That the defendant accepted said statements without making objection thereto. response: 11. That the Defendant defaulted by failing to make payments in the amount set forth on said statements. Response: 12. That, after due demand, the Defendant remains indebted to the Plaintiff in the amount of $xx,xxx plus pre-judgement interest t the statutory rate of 12% per annum, from Oct 2011 to the date of judgement in entered herein. Response: 13. That there are no facts upon which the Defendant relies as a basis for any defense in this action. Response: 14. That there are no documents, writings, letter, records or papers of any sort which the Defendant intends to utilize as evidence of or a basis for a defense in this action. Response. 15. That the material allegations contained in the Plaintiff complaint are true. Response:
  17. I have to finish up discovery, from there, do I wait to ask them to prove they own the account, or do I ask right away? What would be required of them to prove they own it? The itemized list from the original lender?
  18. Included with the papers is a copy of the original signed app. Thanks for all the help with this matter guys.
  19. These seem very generic, and could be used to show the purchase of almost anything, but shouldn't it have my account number or name on it to show they bought my alleged debt? BILL OF SALE The Bill of Sale is entered into this 21st day of February 2011 by and between Absolute Resolution Corporation, as Buyer, and Wells Fargo Bank, N.A., as Seller. Pursuant to the terms of a Purchase Agreement (the "Agreement") dated as of January 10, 2011 and executed by the Buyer and Seller and the Bill of Sale, Buyer hereby purchases and accepts, and Seller hereby sells, assigns, transfers, and conveys to Buyer all its rights, interest and title in and to the Receivables listed on the attached Schedule A. The agreement is incorporated herein and made part as if fully set forth. In the event of a conflict between the terms of this Bill of Sale and those of the Agreement, the terms of the Agreement shall prevail. All defined in the Agreement shall have the same meaning as given in the Agreement when used in this Bill of Sale. Buyer Seller Absolute Resolution Corporation Wells Fargo Bank, N.A. Then it is signed by their Then it is signed by their Chief Operating Officer Executive Vice President Then there is a 2nd Bill of Sale exact to the first only with different company names. It says: Exhibit A BILL OF SALE The Bill of Sale is entered into this 21st day of February 2011 by and between Security Credit Services,LLC as Buyer, and Absolute Resolution Corporation, as Seller. Pursuant to the terms of a Purchase Agreement (the "Agreement") dated as of January 10, 2011 and executed by the Buyer and Seller and the Bill of Sale, Buyer hereby purchases and accepts, and Seller hereby sells, assigns, transfers, and conveys to Buyer all its rights, interest and title in and to the Receivables listed on the attached Schedule A. The agreement is incorporated herein and made part as if fully set forth. In the event of a conflict between the terms of this Bill of Sale and those of the Agreement, the terms of the Agreement shall prevail. All defined in the Agreement shall have the same meaning as given in the Agreement when used in this Bill of Sale. Signed Buyer Seller Security Credit Services, LLC Absolute Resolutions Corp Signed By Their Signed By their Vice President President / CEO Last, there is a page included with this Bill of Sale that is Notary Page...it says State of California County of San Diego On March 17, 2011 before me (the notary), personally appeared (Absolutes President), who proved to me on the basis of satisfactory evidence to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person or the entity upon behalf of which the person acted, executed the instrument. I certify under penalty of perjury under the laws of the state of California that the forgoing paragraph is true and correct. Witness ma hand and official seal Signature of Notary and seal.
  20. If they (the collector) have copies of my statements and proof they were assigned the loan, is my battle over....and should I be looking to settle? Or is there something I am missing? Also, can I file for an extension for discovery? I will be posting discovery info later today or tomorrow. Thanks for the help.
  21. I just received discovery papers today. It is 15 pages long, and at the bottom it states: "this is an attempt to collect a debt. Any information obtained will be used for that purpose. This is a communication from a debt collector." Included with this paperwork are copies for the application for my credit card, and bill of sale from wells fargo to Absolute Resolutions Corp and then Bill of sale from Absolute to Security Credit Services. Both were bought and sold on the same day. I have 30 days to respond. Do I really have to give them my SS# and 3 years tax returns? Also is there a time limit when they can request discovery? Its been 7 months since I was served? Thanks for your help in advance.
  22. Thanks for all the help, I have responded to the complaint. What happens after that?
  23. I edited the first post, and removed the other info. Thanks for all the help so far. I will start drafting my response.
  24. Here we go: First page says Security Credit services V. me 2nd page Very top says security Credit Services llc Assignee of card issuer v. Me COMES NOW the Plaintiff, and for this cause of action against the defendant(s), hearby alleges and states as follows: 1. Plaintiff is a Foreign Corporation 2. Upon Information and belief, Defendant(s) is / are an individual(s) residing in my county. 3. The the defendant(s) applied for a credit card and thereby entered into a contract, and that pursuant thereto the defendant(s) were issued a credit card which is the subject of this action. 4. That this account was validly sold or assigned by CREDITOR to the plaintiff. 5. That the plaintiff is the current holder of said credit card account, and the plaintiff has performed all its obligations under the contract, but the defendant has defaulted by failing to make the payment due thereon. 6. There is now due and owing from defendant(s) to the plaintiff the amount of $..., and no part or portion of same has been paid. 7. Plaintiff requests prejudgment interest as allowed by law. Prejudgement interest accrues from October.....until judgement is entered. 8. Defendant(s) is/are not a member(s) of the Armed Forces of the United States or of its Allies. Wherefore, plaintiff prays for judgement against the Defendant(s), and each of them if more than one, in the amount of $...., plus the costs of this action, prejudgement interest, post-judgement interest, and for such other and further relief as the court deems just. Attorney info This Firm is a Debt Collector. This is an attempt to collect a debt and any information obtained will be used for that purposes.