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I am looking for anyone who has copies of a Bill of Sale or Assignment from Citibank with Patricia Halls signature. I have collected two (from a Cavalry and Midland case) that seem to be different signatures and I suspect robosigning. The wording on the Bill of Sale is also different. I am particularly interested in any notarized signatures from her. This person seems to be on many JDB cases and I am trying to establish if this is like the Mortgage robosigning scandal. These are usually generic forms without any personal information on them, but if there is, you can certainly redact it. I will post my findings here if I get any responses. Thanks!

Hello, I am being sued by Midland Funding original creditor Citibank(Home Depot). I must answer by 5/28/15. I am very willing to fight this to the end, but the amount of evidence/account information included is slightly intimidating. I have reviewed a lot of information on here, but have not been able to find a case with as much up front documentation as I have been provided. I will post all of my documents recieved in the following post. Please give any feedback possible. Thank you for your time.

Hey, Everyone! I have a case in which "evidence" provided by Plaintiff (Portfolio) includes an alleged Bill of Sale signed (possibly robo-signed) by David Nauman of HSBC BANK NEVADA, N.A. and an Affidavit of Sale signed (again, probably robo-signed) by an Ashley Oku of HSBC. I'd like to be able to show that neither are residents of California, but they haven't stated their locations in the documents. Initial internet searches seem to indicate that the former may be in Philadelphia, while the latter seems to be a ghost. Has anyone had a case with either of these individuals named and discovered their places of residence/business? Also, if you know of any documented instances of robo-signing associated with these names, it would be very helpful. Pro pers unite and stand strong!

I just received the plaintiff's response to my plea to the jurisdiction, and special exception I sent off courtesy of the help from Texasrocker. Each reply was in a separate envelope. My court date for this is October 29th so any helpful info will greatly be appreciated. I am just now trying to figure out what the next steps would be or how to properly object to (and get this stuff thrown out) this info they obviously are going to bring up as evidence. The only thing they have my info on is the affidavit from the expert "custodian of records" for Portfolio Recovery, Larry Whitaker. ** Objection hearsay, chain of custody, as Mr. Whitaker is not an expert to the financial records of Citibank...** But the bill of sale from Patricia Hall is very generic. Then behind that is a blank "Exhibit 1 Asset Schedule" it looks like they blanked everything out. Then the printout of all my info from an excel spreadsheet and down @ the bottom says " Data provided by Portfolio Recovery Associates, LLC from electronic records provided by Citibank, NA pursuant to the sale of accounts from Citibank to PRA" In the response, the mention Texas DOT v. Arzate, 159 s.w.3d 188,190( Rex. el paso 2004, no pet) I think it is supposed to be Tex not rex. and then Bland ISD v. Blue, 34 s.w.3d 547,554 (TEX. 2000) --------------------------------------------------------------------------------------- Since they separated the Plea to Jurisdiction and the special exceptions, I will do the same. And again any help will be appreciated.

Please read the post here. I think I found something really good that may help others as well. I just need to know what to include so as not to allow Midland/Asset to come back with updated paperwork that changes anything. Here is the link... Thank you all. http://www.creditinfocenter.com/community/topic/324806-answering-msj-arizona-procedural-question-please/

I'm stressing! I have brain freeze! Not sure what to do now. I have to answer a CCP 96, don't know if I should subpoena a witness that works in Plaintiff's attorney's office - he submitted a CCP 98. HELP! Like I mentioned in another post, I'M in Ventura County, Calif, my case is assigned to Judge O'Neill, don't think he liked me much the 1st time I was in front of him. BV80 Xenophon

I was looking to see what legal requirements were necessary for a Bill of Sale to be binding. It took a bit of digging, but I found this from O.S. 12A Uniform Commercial Code if I am reading this right, this supports the argument that a Bill of Sale must specifically identify the "rights" being transferred. That any Bill of Sale lacking such information is in fact invalid. Is this correct? §12A-1-9-619. Transfer of record or legal title.TRANSFER OF RECORD OR LEGAL TITLE (a) In this section, “transfer statement” means a record authenticated by a secured party stating: (1) that the debtor has defaulted in connection with an obligation secured by specified collateral; (2) that the secured party has exercised its post-default remedies with respect to the collateral; (3) that, by reason of the exercise, a transferee has acquired the rights of the debtor in the collateral; and (4) the name and mailing address of the secured party, debtor, and transferee. ( A transfer statement entitles the transferee to the transfer of record of all rights of the debtor in the collateral specified in the statement in any official filing, recording, registration, or certificate-of-title system covering the collateral. If a transfer statement is presented with the applicable fee and request form to the official or office responsible for maintaining the system, the official or office shall: (1) accept the transfer statement; (2) promptly amend its records to reflect the transfer; and (3) if applicable, issue a new appropriate certificate of title in the name of the transferee. © A transfer of the record or legal title to collateral to a secured party under subsection ( of this section or otherwise is not of itself a disposition of collateral under this article and does not of itself relieve the secured party of its duties under this article. Added by Laws 2000, c. 371, § 126, eff. July 1, 2001.

1. Who is the named plaintiff in the suit? Cach, LLC 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Neuheisel Law Firm 3. How much are you being sued for? 9k 4. Who is the original creditor? (if not the Plaintiff) Wells Fargo 5. How do you know you are being sued? (You were served, right?) Yes 6. How were you served? (Mail, In person, Notice on door) At front door 7. Was the service legal as required by your state? I believe so Process Service Requirements by State - Summons Complaint 8. What was your correspondence (if any) with the people suing you before you think you were being sued? Letter requesting dv 9. What state and county do you live in? AZ 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) 2011 - still within sol 11. What is the SOL on the debt? 2014 12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). did summons, did answer, now in discovery: was sent req for non uniform interrogatories and also Req production of docs and also Req for admission of facts and non uniform interrogatories. All in same packet. 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No, not yet....too late? 14. Did you request debt validation before the suit was filed? no Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. 15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? august 12 and yes Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits 16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. Bill of sale, statements with my name and address, something that looks like part of my credit report, terms and conditions 17. Read this article: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits I have read through like threads for months and have learned and understood much of how to respond to most of this req for info however, I need assistance responding to some specific items. I did post a question a couple of days ago but it was under a similar thread and no one answered it so I thought I better just open my own thread at this point. Here are some questions I am having difficulty with: REQUEST FOR ADMISSION OF FACTS AND NON UNIFORM INTERROGATORIES 10. Admit that Plaintiff is the successor in interest to wells fargo bank with regard to the credit card acct #XXX. See Bill of Sale attached hereto as Exhibit C and incorporated herein by reference 11. Admit that plaintiff as successor in interest to wells fardo bank is owed at least 9k pursuant to the bill of sale, which is attached hereto as Exhibit C and incorporated herein by reference. and then the following questions on same Request: 15. admit the original creditors credit card acct appear on Transunion credit bureau. See copy of your credit bureau attached hereto as Exhibit D 16. Admit that you never disputed this acct with any of the three major credit reporting agencies. 17. admit that you have provided Plaintiff with no doc supporting any affirmative defense against the Plaintiff complaint in this action. OK, so 10 and 11 refer to the bill of sale that looks like it was copied a hundred times with no ref to acct in question except as an Exhibit A. I already plan to file a motion to strike this from being admitted as evidence from what I have read about it's being heresay. But I am not sure how to word it properly, all I have written is that I have filed motion to strike this. Is this all I need to say? do I file this same day I take my responses to court clerk to file that? As for the other questions, no I didnt check or dispute my credit report for this because I didnt know it was there and as a knucklehead dont check my credit report as often as I should, apparently. so can anyone help me with how I should respond to these questions? I've been working on this thing for weeks and now I'm getting incoherent and will probably pass out very soon from lack of fresh air. Some one please help? (ps if anyone needs to see any of the docs I can attach just let me know what you need to see) .

Okay so I sent req. for prod of docs and rec'd a few things back...one of which is a very generic bill of sale- I have a few questions about it.