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  1. I'd like to find a way to discourage Midland from filing a lawsuit against me for a JC Penney account they claim they now own. From what I understand, JC Penney cards are issued by GE Money Bank, and that GE Money Bank's agreements operate under the laws of Utah. Unless a change in the account's ownership changes this, this would mean there is a 6-year Statute of Limitations which won't expire until next year. Midland recently sent me a settlement offer that I wanted to respond to in a way that may prevent them from proceeding with a lawsuit. If I sent a letter to Midland that conveys the fact that i would file a general denial, proceed with a Request for Production, and defend myself at trial, I thought this may be enough to discourage them from filing a lawsuit against me. Am I underestimating them?
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