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End Games w/ Cap One-- quick tip please.


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I have posted the background on this case with Capital One in other threads but it looks like I am entering the final stages of this case.

I am wondering if anyone can give me a little guidance on my options at this point.

We are still in the Discovery phase -- I submitted my responses to Cap One's request for admission, production of docs and interrogatories. I also submitted my own discovery requests, i.e. request for admissions, production of docs and interrogatories, on the 31st of January.

On the 15th of February I submitted a Motion to Deem Admissions Admitted exactly 14 days when it was due. On February 19 Cap One filed a Motion to Strike my Motion to Deem and requested a 30 day extension to answer. The judge in this case denied my motion saying it was not made in "good faith" and granted a 30 day extension to answer my discovery requests.

Shortly thereafter I received a letter from Cap One containing a signed copy of an application from 2001 and the last credit card statement from September 2009. Today I received a Second Motion for Extension of Time to Answer my request for Admissions and Interrogatories.

At the moment I am researching my options as to how to respond to Cap One's letter containing the signed application and last statement.

I am wondering if it would do me any good to contact Cap One's attorney and just make them aware that I am willing to take this to trial and that if they get a judgment against me then I will file for bankruptcy. I am thinking that they might reconsider pursuing me relentlessly for $3,959 and investing more time and money into a case that even if they do win they will not be able to collect on.

I have had some leads on possible defenses from some helpful posters on this site that I am currently looking. It would help me out if anyone knows where I can find clarification as to whether an application for credit is the same as a signed contract? Its seems that Capital One assumes that an application for credit is the same as a contract.... what is the basis for their assumption?

Also, it was mentioned by someone that a contract in writing would expire in the second or third year after the issuance of the credit card. But I am unable to find mention anywhere on the signed credit card application of contracts expiring in 2-3 years??

There is a case, MFRS TRUST CO v. Lindauer, which does mention something to the effect that employment of the provision -- "We can cancel your account at any time" -- provides the contractual basis for the adopted practice of a bank in limiting the validity of its credit cards for a two-year period. The section of "important disclosures and miscellaneous info" on the reverse of the credit card application does include this particular provision. But I am unable to find any specific mention of this 2 or 3 year expiration after the issuance of the card. The case did make mention of the fact that the terms of the contract are implied by the use of the card.

Perhaps I am grasping at straws with this.

I have thought about filing a motion (I am not sure what type of motion?) to strike their submitted signed application and final statement as these do not definitively tie me to their claim of contractual terms and the amount of debt they claim I owe. However, the letter they sent me was not an official court document submitted but rather seems more like an attempt to have me admit to the debt and settle as it was worded in such a way.

In regards to Cap One's Second Motion for Extension of Time to Answer discovery requests received today. The requests are due around the 15th or 21st of March... they want an additional 30 days to answer. Their Motion states that "the requested enlargement of time will not prejudice the Defendant". I am not sure how many requests for additional time is reasonable to a judge. Could I file a Motion to Strike Defendant's request???

Given the fact that they brought this case against me shouldn't they have evidence readily available??? Also, additional time does prejudice me as having this case drag on puts a strain on my time and resources, right?

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Its seems that Capital One assumes that an application for credit is the same as a contract.... what is the basis for their assumption?

I don't know if this is correct or not, but I'm going to offer one possibility. As I, along with others, have stated on this board many times, a cardmember agreement usually states that use of the card indicates acceptance of the terms and conditions. I wonder if it could be argued that, barring ID theft, they have proof you applied for the card, and your use of that card shows your acceptance with the terms and conditions of the cardmember agreement. Since the cardmember agreement includes terms of payment, your use of the card created an agreement or "contract" between a creditor and debtor.

I have thought about filing a motion (I am not sure what type of motion?) to strike their submitted signed application and final statement as these do not definitively tie me to their claim of contractual terms and the amount of debt they claim I owe.

I don't know if it ties you to their claims of contractual terms, but it does prove you applied for and used the card. Unless you disputed charges as unauthorized or ID theft, I assume the final statement shows the balance they're claiming is owed.

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I am wondering if it would do me any good to contact Cap One's attorney and just make them aware that I am willing to take this to trial and that if they get a judgment against me then I will file for bankruptcy.

no dont do that. that can spiral out of control, and not in your favor. its one thing if you've already filed bankruptcy papers.

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BV80... thanks for the reply. The use of the credit card indicating acceptance of the terms and conditions sounds about right. Just throwing spaghetti against the wall.

jackson212... I do realize that contacting Cap One's attorney is something that may do more harm than good. But after receiving their Second Motion for Extension of Time I am trying to explore all options. Since Cap One has not answered my discovery requests in the set time frame and is asking for MORE time, there must be something I can do. I was looking into a Motion to Compel discovery but came across FRCP 37 which states

"On notice to other parties and all affected persons, a party may move for an order compelling disclosure or discovery. The motion must include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action."

I take this to mean that I should at least attempt to contact Cap One's attorney BEFORE filing a Motion to Compel. I am not sure if the judge would accept an Objection to Plaintiff's Second Motion for Extension of Time if I haven't even filed a Motion to Compel, or even made a "good faith" effort to contact the Plaintiff about my discovery requests.

Does anyone think that a second motion for extension of time is unreasonable considering the Plaintiff, who initiated this suit, does not have the requested documents readily available?

If so, what are my options at this point? Should I just wait around another month for them to get around to responding? I am not sure what "conferring or attempting to confer" actually means or what good it would do me at this point.

As I said before, if I did contact their attorney and just made slight mention or even allude to going to trial and being judgment proof, could this have the desired effect of Cap One rethinking the costs of persuing a judgment or is this just wishful thinking?

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First of all, I am in the same boat as you are relative to discovery being a seemingly never ending process if the idiot JDB is intent on delaying it. I sent discovery off over 2 months ago a just did last week get a response and that response had NO documentation and claims that they were still in the process of unearthing proof.

I have just to decided to just sit back and laugh at the idiots in their conduct up to this point and just wait and see if they intend to provide anything substantial.

I REALLY liked your tactic of filing in advance. I did the same thing when I filed a motion to dismiss in my case where the idiot JDB barely beat the court ordered extension for time to anwser my discovery requests, they actually were late by one day. No way was i going to give them another week to ten days by waiting for the deadline to pass before I filed to dismiss.

What BS that the judge would say you made the motion in bad faith, especially if you hadn't even asked for a court date (did you request a court date?). Its like people don't have anything else going on in their lives that we are just required to wait for an infinite amount of time for these fools to prove their claim.

I have to say though that the fact that they provided a signed application is more than I have heard they usually provide. And the last statement too.

But again as far as the discovery, I TOTALLY share your opinion that it is ludacris that the courts allow the morons so much time to gather proof of their claims when they are the ones bringing the suit, especially when this is proof that they were looking for a default in which they wouldn't have to prove anything, but it seems like these courts could care less how much time elapses and how long you are held in limbo.

I do know that you will not be able to file a motion to dismiss until the stupid discovery phase is over, because they can get it dismissed by simply saying discovery has not been completed.

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As for your question on an attempt to confer, I will reply a bit cynically with regard to the seemingly endless nature of discovery when the JDB has no proof but wants to endlessly delay in hopes they can unearth something.

Attempting to confer in discovery means that you are making an effort to resolve things without getting a court order. I believe this is typically done in writing, you write back to the party informing them that their anwsers are unsatisfactory or violating rules of discovery and ask for amended responses, and then they get another 10 days to respons back to that. Then if they don't, then you go back to the judge and they get another extension, probably another 20 to 30 days. Then they probably send you back more BS evasive anwsers...lol

Again, from my experiance it seems that the JDB basically gets to determine when discovery is over and when they want to move forward with whatever they have. Judging by the a-hole response to your motion from the judge that you mentioned, I would just hold out hope that he will actually demand that they provide adaquate proof of the alleged debt and pretty much give up on getting this resolved before the clowns decide discovery has come and went.

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As I said before, if I did contact their attorney and just made slight mention or even allude to going to trial and being judgment proof, could this have the desired effect of Cap One rethinking the costs of persuing a judgment or is this just wishful thinking?

My tact was to always include the below in any communications, whether it was to the OC or its agent, validation request or otherwise:

Following is a simple list of realities you may wish to consider:

Indigent? Yes.

Judgment proof? Yes.

Adamantly deny your asserted claims? Yes.

Will fight legally to the nth degree? Yes.

Bankruptcy ready? Yes.

If your side should “win”, you still lose…

(Copy sent to *****OC)

-----------------------

I always figured it couldn't hurt....

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I went into one of two credit unions that I deal with. Had a question on my account which is current and in good standing. The question I had was, when I originally got my card, did I sign up for credit Life? They pulled up my account and showed me my original aplication from about ten years ago showing that I had. Funny thing was, someone forgot to charge me each month for it, thus, I had no credit life on the account which, as I explained to them, protected them after I was dead....lol.

The point I am making here, is that they had scanned in my original application and showed me everything I had put on it as though I was looking at the hard copy from ten years ago. So, some banks do have their paper work in order. Just be careful.

Tom

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I think you are going to really have an uphill battle on your hands, you have reversed a judgement, been accused of having someone write your pleadings. You have upset the debt collection apple cart from the court and plaintiff's attorney perspective.

To me it appears they have fired a shot over the bow by sending you your signed application for the card and a statement. This means they are asking for more time to get the rest of the documents together, and the judge is going to give it to them.

Obviously if you go all the way to trial they are going to have to provide a witness to go along with any affidavit. But they either already had or were about to have their hand in your bank account, this is like blood in the water for a shark.

As this is Crap One, I would check your rules of procedure regarding using the arbitration strategy. You have never mentioned the amount of the debt, but Crap One usually doesn't let folks get over $5K in debt, unless you had sterling credit. Point is if your debt is $10K or less, the cost to go to arbitration may be cost prohibative. This doesn't mean they will give up, but you could stretch this out for a good long while. A stong consideration in arbitration many of the banks will immediately go for choice of law provision in the card agreement. For Crap One this is Virginia Law and 3 yr. SOL. You usually can't get this in court, but in arb you maybe able to.

It is hard to win in mayberry court where the attorney's and judges work so closely day in and day out.

Best of Luck...

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So then my next step should be to send a letter to Cap One's attorney mentioning the fact that they initiated this action and therefore presumably should have direct access to the evidence I requested in discovery... then question the length of time it is taking them to respond to discovery and how this is inconveniencing me by putting a strain on my time and money. And then in a subtle manner mention my dire financial situation alluding to possibly filing bankruptcy which is why I would like to have this resolved(?).

If I do attempt to confer with the plaintiff should I mention the docs that they send informally, i.e. signed application and final account statement, and mention how these in no way tie me to this alleged account? For example, the signed application does not have an account number that would tie me to this account. They did not provide a complete accounting for the amount they are claiming or state what goods or services were allegedly provided. I would think this is pretty standard evidence a creditor should have on hand in order to prove their case.

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I don't think you are going to rattle them in anyway using the court system. This is their playground and they know the rules (civil procedure) better than you ever will, futher they know how far the judge will let them go outside the rules of the play ground. They play on the playground 365, 24/7, you are only a guest.

Threatening BK is worthless also, the CA that had my account with Cap One got paid on % collected and had pre-set guidelines of settlement they could entertain. They could care less if you file BK, it doesn't change their business model, other than you move out of their computer system and another file moves in.

From my personal experience the only thing that changed my Crap One case was Motion to Compeling Arbitration, even after I won my motion, they still proceed as though they were in control. As soon as the CA got the first bill for $550.00 from the private arbitration forum they needed to pay. They suddenly became much nicer to speak with and settlement was reached.

Something to consider, as far as discovery Crap One keeps everything in my experience so they will eventually have all the statements, to go with your signed application and final statement they sent.

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I have heard mention of taking this into arbitration which I have yet to research. From what I understand, arbitration is working with a third party instead of a judge who plays a similar role and whose decision is binding. I will look into this, but if anyone can please clarify the advantages of arbitration as opposed to the courtroom that would be appreciated.

Is arbitration a forum creditors prefer as opposed to the court?

Is it more favorable or advantageous to either party?

Are judges generally inclinded to grant motions to compel arbitration?

Do decisions made in arbitration have the same effect as those made in court?

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you may have them on "failure to conduct reasonable attorney review", violation of 15 usc 1692. see the miller case in my sig. what you may want to do....if you allow them more time for discovery, you need to find out what they knew and or what docs they had when they filed this lawsuit. they wont know, but you are now setting them up for a lawsuit for failure to conduct reasonable attorney review prior to filing this lawsuit.

it cant hurt to be strategic, figure if they're gonna get more time, use that to your advantage.

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I have heard mention of taking this into arbitration which I have yet to research. From what I understand, arbitration is working with a third party instead of a judge who plays a similar role and whose decision is binding. I will look into this, but if anyone can please clarify the advantages of arbitration as opposed to the courtroom that would be appreciated.

Is arbitration a forum creditors prefer as opposed to the court? No, creditors don't like it, but consumers do. Often it will cost the creditor more than they are trying to collect, so they will often dismiss rather than pay the fees.

Is it more favorable or advantageous to either party?Advantageous to the consumer for many reasons

Are judges generally inclinded to grant motions to compel arbitration?They don't have to be inclined. If the agreement has an arbitration provision, it is "out" of the jurisdiction of the court. It only has to be pointed out to the judge by showing them the agreement and that you elect arbitration.

Do decisions made in arbitration have the same effect as those made in court?You have more options in arbitration - depending on your case. For instance, a consumer's state may have a longer sol that if taken to court, the court will use the consumer's state sol. However, in arbitration, you can often use the cardmember's agreement sol that governs the contract, like Delaware or Virginia which has a shorter sol (3 years). Also even if the consumer loses, the creditor still has to go back to court to get the award confirmed and some times, they don't do it or even run out of time and the consumer is off the hook. And even if they do confirm it, all this takes time and sometimes the consumer is trying to buy some time to get things in order to file BK and there is plenty of time to do this through arbitration.

See parts in red above. :)++

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I think Linda did a nice job answering many of the questions generally. You need to research further for yourself. You may want to do the research on www.debtorboards.com.

There is some good information here on CIC, just much more robust activity on the other site and more updated information, real time so to speak.

IMO the first advantage is the arb forum rules are much easier to understand and follow versus civil procedures in court, it is less formal which for pro se is better also. Although you have proven that you can write pleadings at a high level, so not a big deal for you.

Biggest advantage is the cost of the proceeding is almost entirely born by the business, based on their card agreements. These costs make a difference in their decision making process. Going to court is computed into the business model for the CA, when you take that cost from let's say $500 bucks and it could be$8K-$10K to get the case heard at a arb hearing. The buisness really has to consider if you are worth pursing. In most instances these costs aren't recoverable in the arb award should you loose.

Finally as Linda pointed out they still have to go to court to confirm the arb award, still more battling for them. Be mindful arb isn't a walk in the park, you will need to work at your goal in using it, but with research and learning a good number of folks are reaching better settlement offers, so CA just give up and sell the debt to the next guy.

Best of Luck in which ever direction you go, you are doing well so far in court so maybe that is the direction you should stay with.....

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These costs depend on the forum, JAMS is the more expensive. Typically it goes something like this-

$800.00 initiation fee- Depending on who initiates the claim, consumer may have to $250 of this depending on contract language, court orders.

$2000.00 Comencement Fee- This sole responsibility of the business, OC, CA, JDB, and is only due if the initiation fee is paid.

Hearing Fees- are based on individual arbitrators rate but range between $400-600 per hour, typically they ask for one days worth of hearing fees, prior to the hearing and is paid by the OC, CA or JDB.

So you can see that we haven't included any lawyer representation fees for any of this yet, as Linda says any debt under $5K arb should get real consideration.

You need to review contract for which arb forums are included, AAA is much less costly than JAMS.

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Are all of those fees something they can then add on to whatever judgement they are able to get?? Probably yes.

I could see the sense of doing arbitration even if they can as they probably wouldn't want to spend that much out of pocket, and then their victim end up filing BK.

In my situation I am leaning against arbitration as I am confident that KRS 371.050 a statute in my state that says that an assignee of a debt can only collect what they paid for the debt is a real trump card that I wouldn't have in arbitration.

I suppose I could still opt for arbitration even though I haven't used it as a affirmative defense. I have asked for a contract with terms and conditions and until I get that, I don't even know whether or not an arbitration clause governs the account the JDB is alleging that I owe them. If I ever get a contract produced by them and the arb clause is in there, I guess I would have to choose one way or another.

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Are all of those fees something they can then add on to whatever judgement they are able to get?? Probably yes.

This is where the cardagreement language is important, 2009 and before most agreements say they will pick-up the entire tab, 2010 and after each are a bit different, so you need to do your research on your account and date of default.

There are other protections, consumer arbitration by nature was intended to be a less costly dispute resolution. So the forum itself has rules of consumer protection and then of coarse there are state laws. Example California the most a consumer can pay to go to arbitration is $250, and all other fees are borne by the company win or loose.

I have yet to see anyone post they have lost in arbitration, doesn't mean there aren't some, most are some form of settlement. I didn't want to push to the hearing and managed settlement of 18% of debt. Some would say that is even high for arb.

It is simply another tool to consider, when court isn't going very well.

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during discovery, ask for a full accounting (not just the last statement) to determine how the amount owed was calculated, including interest.

IF they provide statements then -

first, go thru each statement paying attention to -

1- completeness....are there any months missing?

2- do they go back all the way to the very first statement?

if the yes to 1 or both, then attack as you cant verify that interest was calculated properly as statements are missing.

I have to say though that the fact that they provided a signed application is.....

this is a stunner for me too.....took me a few minutes to reattach my jaw to my head after reading this.

amazing that they have the signed contract from 10 years ago!!88-)

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Thanks for all of the leads and advise... it does look like I have a lot of research to do but I will consider every angle.

Today I received in the mail what I initially feared to be a knock out blow from Cap One. Cap One's attorney Kramer & Frank sent me their responses to my first request for Production of Documents, which included a copy of a signed credit application from 2001 (the same one mailed informally) as well as statements from Nov 2008 to Sept 2009.

However, as I took a closer look at the submitted documents I see some problems with their response. For one, the statements from Nov 08 to Sept '09 do not give a full account of how the alleged amount of $3,958.90 was calculated, which is what I had requested. The Nov '08 statement begins with a balance at $2,217.05. Does the fact that this is not a full account of how the alleged amount was calculated reveal insufficient evidence to support their claim? Would a judge find this insufficient to win a judgment?

As I went through the one page statements each with several pages of unnecessary info, such as front and back copies of "purchase checks" solicitations along with information about the checks and info on transferring balances, all of which have absolutely nothing to do with the case.

They also included a copy of a "Capital One Cycle Facsimile Report", which I find extremely difficult to follow, a two page copy of a "Customer Agreement" and lo and behold a copy of an "Arbitration Agreement" which states in the first line "You and we agree that either you or we may at either party's sole election, require that any Claim (as defined below) be resolved by binding arbitration."

I was going to research in depth the possibility of arbitration but before I do so was hoping to get a few more questions answered.

From what I understand, if I do decide to request arbitration there is a cost associated with this, right? Can either the judge or plaintiff challenge this request?

Also, the purpose in electing to go into arbitration seems to be to buy more time and to ideally frustrate the plaintiff into investing more time and resources into a suit over a meager amount which may result in a dismissal (?).

On the other hand, arbitration could raise the costs for me as well and if Cap One should decide to pursue this all the way, which thus far seems to be their intent, could this lead to exorbitant fees that I may have to pay should I lose the case (?).

I have posted below a copy of the Plaintiff's answer to my requests.... based on this situation I now find myself in, what should be my plan of attack at this point....

1. The alleged credit application from “Account” bearing the Defendant’s signature.

RESPONSE: Objection. The request assumes facts not in evidence as Plaintiff often processes credit card applications via telephone or internet for the convenience of its customers. Accordingly it is not necessarily so that there would have been a signed writing. Without waiving the objection, please see attached Customer Agreement to which Defendant was bound by his receipt and use of the card.

2. The alleged credit agreement from “Account” that states interest rate, grace period, terms of repayment, et cetera.

RESPONSE: Please see attached Customer Agreement.

3. Itemized statements or credit card statements from “Account” that demonstrate how the alleged amount of $3,958.90 was calculated.

RESPONSE: Please see attached itemized statements.

4. Documentation showing the date this “Account” went into default.

REPONSE: Please see attached itemized statements.

5. A contract, agreement, assignment, or other means demonstrating that Plaintiff had the authority and capacity, and was legally entitled to collect on the alleged debt from “Account”.

RESPONSE: Objection. The request assumes facts not in evidence by assuming the account was assigned. This account was not assigned as Plaintiff is the original entity from which Defendant opened account.

6. Letter(s) sent to Defendant by Plaintiff, demonstrating an attempt to collect on the alleged debt, “Account”.

RESPONSE: Please see attached Demand Letters.

7. A notarized statement, if presently existing or otherwise, by a person with original knowledge of the alleged debt, as it was constituted, and who can testify, or be so interrogated in a deposition, that the alleged debt was incurred legally;

RESPONSE: These responses are tendered with the understanding that, as to all matters of grammar and syntax, they are responses prepared entirley by counsel, that the word usage and sentense structure is not the word usage and sentence structure of Plaintiff, and that Plaintiff will object to any suggestion to the contrary.

8. Any and all further documents that you believe establish that Defendant had an outstanding debt related to alleged “Account”.

RESPONSE: Plaintiff has attached hereto documents associated with the credit card account at issue.

9. Any further documentation, beyond what has been previously requested, that clearly establishes Defendant’s liability and/or responsibility to the alleged debt;

RESPONSE: Plaintiff has attached hereto documents associated with the credit card account at issue.

10. Any and all credit report(s) Plaintiff obtained from any credit reporting agency concerning the Defendant.

RESPONSE: N/A. Plaintiff has attached hereto documents associated with the credit card account at issue.

11. Any and all notes, memoranda, or likewise, be they handwritten, computerized, or typed, regularly kept in the normal transaction and business of collecting debts, that relate to the Defendant and/or “Account”.

RESPONSE: Plaintiff has attached hereto documents associated with the credit card account at issue.

12. All DOCUMENTS relating to any communications between Plaintiff and Defendant with respect to the alleged “Account”.

RESPONSE: Plaintiff has attached hereto documents associated with the credit card account at issue.

13. All DOCUMENTS relating to any communications between Plaintiff and Original Creditor with respect to the alleged “Account”.

RESPONSE: Plaintiff has attached hereto documents associated with the credit card account at issue.

14. All copies of charges slips signed by defendant, with the original creditor.

REPONSE: Orders, charge slips and the like are the property of the merchant and the customer and so do not come into the possession of Plaintiff. However, please see itemized statements attached hereto.

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From what I understand, if I do decide to request arbitration there is a cost associated with this, right? Can either the judge or plaintiff challenge this request?

Below is from the Crap One agreement I have related to costs-Check the agreement you recieved as there maybe changes based on date of agreement.

Costs. The party initiating arbitration will pay the initial filing fee. You may seek a waiver of the initial filing fee or of the Administrators other fees (collectively “Arbitrators Fees”) under any applicable rules of the Administrator. If you seek but do not qualify for a waiver, we will consider any written request by you to us to pay or reimburse you for all or part of the Arbitrators fees. If the Arbitrator determines there is a good reason for us to do so. We will pay any fees and costs we are required to pay by law. Otherwise, and except provided by this agreement you and we will bear all of our respective fees and cost (including the Administrators Fee) and the fees and costs relating to attorneys, experts and witnesses, regardless of who prevails. Allocation of fees and costs related to appeals in arbitration will be handled in the same manner

Upon review you will see that typically you will be responsible for $250 which is the JAMS consumer fee, although you may qualify for a waiver, or can ask them to pay. Further, if you use the court to Motion to Compel the court may order them to initiate as they are suing you, then they pay everything. According to cardagreement "regardless of who prevails" they pay for all their attorney fee's, experts and witness, Arb fees's, and you pay for yours, oops you are pro se you have no costs, other than time and hard work....

You need to check your rules of civil procedure, you can sometime litigate in court to long and courts will say by going to arb now you have predjudiced the other side. Although as they just now supplied the contract with the arb langauge, you can easily say "I just recieved the contract, so I brought MTC arb, had plaintiff supplied contract at time they filed the suit I would have moved sooner".

As previous check all this out prior to making a decision...

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