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Showing results for tags 'unclean hands'.
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I recently received Complaint from attorneys of Cavalry SPV 1 containing a falsified credit card statement. The most glaring tip off is that the alleged monthly “account summary” contains columns of figures with misaligned decimal points. Citibank statements would not contain this ham handed mistake. Otherwise the statement appears believable upon a cursory look. Any idea how to establish this seemingly obvious yet difficult to substantiate falsification?
I'm getting my response and Affirmative Defenses ready for a Summons served. Cavalry included a Bill of Sale and Assignment from the OC that they claimed in Accusation 2 to be true and accurate (which I'm denying). Upon further examination, this "true and accurate" document marked as Exhibit A in the Summons is also marked as Exhibit C on the document as well. Additionally, the copy has a date marking that's 13 days behind the alleged origination date. To me, it appears this document has been used on multiple occasions in a cut and paste fashion. Should I point this out in my Affirmative Defenses, and is this evidence of Unclean Hands due to the fact the BOS is inaccurate? Thanks in advance for the input.