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Normally, yes. But Midland possesses no accurate Account agreement where this is indicated, nor can Johnson Mark prove any agreement terms that this account may be governed by. CIT Online Bank's parent co., The CIT Group, is a bank organized in Delaware, which you can prove. Due to lack of any valid terms, Delaware law prevails. See Utah law I provided.

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I just want to be very sure of my objections before filing this time because they have been ignoring everything I send. I need to object to this current Motion for decision as well as object to the bill of sale and affidavits. If I can add in objections based on time barred debt that would be great but everything I've looked at is extremely vague when it comes to Utah law and using another states jurisdiction. I'm trying to see if Dell/Cit uses a choice of law clause in their contracts but I'm not having any luck. 

 

I don't have the original contract unfortunately.

 

Would it hurt my case to use the defenses even if they say they can't be used?

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I understand your concerns, and they're entirely valid. If it were my case, I, too, would be playing it very safe. But know where your latitudes lie by knowing your jurisdiction's Rules of procedure. Go onto Lexis and get a free account and research debtor cases for (your hometown), Utah, and determine what worked in debt cases. You mentioned earlier that you're just 'so busy', but this challenge merits description as being right now, the fight of your current life: Find time without sleep and research how to now approach this.

Find some lawful action that gets this information in front of a judge first, copy to Plaintiff. It's either declaratory or summary judgment. Declaratory allows you to claim damages, which I think you're entirely entitled to, due to their misconduct. Forget about plaintiff ignoring you, this is no longer about discovery, this becomes a communication between you and the judge directly.

Also, recognize as an added advantage that Midland is now JDB No. 3. The assignment waters and obtaining pertinent contracts and 'agreements' to prove your non-compliance of those original terms are now so muddied and so far removed from CIT, that any original contract terms are impossible for Johnson Mark to prove. That they've inserted an 'Agreement' from 7 years prior to your alleged default into the legal record as their indication that you now owe them shows that they are entirely desperate and REALLY grasping for straws. By you raising these sudden 'issues of doubt' requires them to remedy any genuine controversy--and this would qualify. Its obvious to me that they can't. Recognize also that Johnson Mark is no longer interested in playing fair, if they ever were. They're pulling extreme BS by way of 'sanctions' and 'motions', now they're accusing you of not cooperating. Recognize that your strategy to fight this needs to change, this gentleman's dispute is no longer polite. You need to shift into new thinking, become more aggressive as they have, and consider extreme measures. Determine what your options are to block any of their intent to bring this case to an upcoming close, by introducing items that dispute their claims, while there's still time, and that are indicative of their obvious jackassery.

Your job as a defendant isn't to prove anyone's case. But to win-- you'll have to inject doubt. Raise notions that things aren't as they may seem. You'll find them everywhere if you look deep enough. Here's one: That a professional lawyer found it acceptable to include a 7 year-old, outdated credit agreement that you were never a party to, acceptable to prove his case? Might there be just a little far-fetched desperation in thinking that there was any relevance to your case that this eleven year old agreement could possibly provide? Could it then be deduced that a 2002 credit agreement holds no legitimacy to this legal matter, and everything within it proposed must be entirely suspect? We have to recognize with sympathy that this far outdated agreement was what was presented to them as part of any skimpy documents during a supposed conveyance. But how has legitimate conveyance been proven? Has that been proven? Have you been provided with the Account Purchase Agreement, as Ken WA mentioned? Did Plaintiff acquire this outdated credit agreement through this conveyance or was it only what was available through an internet search? What obstacle presents that Plaintiff is reduced to presenting such an outdated instrument? Why weren't previous, alleged debt-owners of this account able to provide 'current' credit agreements? That Plaintiff can't provide something in any way current, erodes Plaintiff's credibility in this matter.

They're about to win this case against you, through their underhanded filings. Pull out all weapons. You aren't penalized if you're wrong, its a built-in cushion as representing pro se. It's their case to prove. Trying to collect on SOL is an immediate void to this case. That they can't provide or prove exactly what law this debt is governed hurts their position. Take advantage of the swiss cheese they've provided. Argue that.

Cause of Action: For what reason have you brought this complaint?

You haven't brought a complaint. Plaintiff brought this complaint. Plaintiff holds the cause of action that they cannot prove. One brings a complaint before the court because they're looking to 'recover'. Recover what? Money. Sanctions. Sometimes prevention of the other party from ever doing that specific behavior ever again. Well, why? How has Plaintiff been 'harmed'? In what way has their original condition been negatively changed that they seek redemption for, that only a court of law can solve?

Think about that. How has Midland been harmed? Midland is the largest junk debt buyer in this country. Midland boasts on its website about how little it has paid for it's ongoing financial success (+/-$25 million), yet has 'recovered' for itself by way of the legal system and the un-education and intimidation of the American consumer when it comes to consumer law, over 36 Billion Dollars. Midland bought your $2400.00 debt as a third JDB for three cents on the dollar. $2400.00 X .03 = $72.00. Midland is now aggressively pursuing you on a debt it can't prove is valid, due to a questionable SOL, can't prove ownership because it refuses to share with you its purchasing agreement and instrument of conveyance and instead hopes to recover 'full value', plus its added on, undeserved fees + atty fees.

Midland entered into a confidential purchasing agreement with Dell and bought an undetermined boatload of 'bad debt/uncollectable debt/abandoned debt' that was well-known to Midland at time of purchase to be unwarranted, inaccurate in amounts due, possibly discharged thru bankruptcy, expired SOL but chose to purchase this non-guaranteed portfolio anyway. Midland's business model relies on entering into buyer-beware-purchasing agreements and entered into this agreement that allegedly contained your charged-off debt at their own financial risk. They've contributed to their own 'harm' and are entirely and solely complicit in their $72.00 loss. But yet, according to your initial post, they've been hounding you by way of the expensive atty fees of local pitbull atty firm Johnson Mark for almost a year now. Surely their cost-to-benefit ratio has been long ago exceeded by this maniacal, locked-jaw endurance of chasing you for what may become only a $3,000.00 judgment. This dogged pursuit with absolutely no standing defies the typical default on a contract experience. One has to wonder: What motivates them to continue such a legal pursuit, on an un-provable cause of action, in light of other, more easily caught debtor fish?

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 I'm trying to see if Dell/Cit uses a choice of law clause in their contracts but I'm not having any luck. 

 

 

 

 

 

...one more thing. You probably won't find a choice of law clause with Dell/CIT. They are no longer affiliated. Dell bought out CIT's 30% ownership of Dell Financial in 2007, I think. (DingDingDing- No paper trail for Johnson Mark)

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Do you think I could use this in my objection regarding the sanction? 

 

Rule 26(d)(1) A party shall make disclosures and responses to discovery based on the information then known or reasonably available to the party.

 

And then maybe this in regards to their supplemental disclosure? 

 

Rule 26(d)(4) If a party fails to disclose or to supplement timely a disclosure or response to discovery, that party may not use the undisclosed witness, document or material at any hearing or trial unless the failure is harmless or the party shows good cause for the failure.

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Here is the objection I came up with....

 

 

THIRD JUDICIAL DISTRICT COURT

STATE OF UTAH SALT LAKE COUNTY, SALT LAKE DEPARTMENT

 

MIDLAND FUNDING LLC,                            |                      

                             VS                                                  |                       Case No.

                                            |                       Judge: Judge Collection

 

Defendant’s opposition to Plaintiffs’ Motion for Sanctions on May 16th 2013

1.    Introduction

Defendant submits this opposition to Plaintiffs’ Motion for Sanctions.

 

Pursuant to Utah State Rules of Civil Procedure 26(d)(1) A party shall make disclosures and responses to discovery based on the information then known or reasonably available to the party. The Defendant has provided the Plaintiff with all documents in possession, care or control at present and will further provide any new documents that come into possession in the future.

 

2.    Plaintiff has failed to show that the Defendant willfully and blatantly refused to provide requested documentation.

The Plaintiffs argument set in Request to Submit for Decision on September 5th 2013 that the Defendant has “shirked” the requirements set out by the Court is an unfounded personal attack upon the Defendant and has no grounds for requesting sanctions as the order to comply has been followed to completion as per paragraph 1.

 

3.    Plaintiff has willfully pursued a time barred account.

It has been further brought to the Defendants attention per recent documents received on August 21st 2013 from Plaintiff that the state of issue for this alleged account is listed as Delaware and as such the Plaintiff is pursuing a time barred account per statute of limitations on both written and oral contracts in Delaware is barred at three years. As Plaintiff was aware of state of issue they are in direct opposition of Federal Civil Procedure code 11 for willfully filing for improper purpose, such as to harass,

 

 

cause unnecessary delay, or needlessly increase cost of litigation. The above paragraph will be followed by a formal complaint against Plaintiff and all counsel involved in the listed action.

 

 

It is the wish of the Defendant for Motion for Sanctions to be dismissed and the original pleading be sustained as all requests and orders have been followed as per rule 26(d)(1).

 

 

Signature____________________________________    Date:

 

 

 

Please give me feedback asap!

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Here’s what I would correct:
 
 
 
1. second line  Defendant….(needs an apostrophe between T and S)
 
2. Its been further brought to the Defendant’s attention that:
 
  a. Plaintiff has filed as legal record a purported credit agreement, discovered by it’s facsimile time-stamp as having been transferred on 9/4/2002.
 
  b. Defendant’s alleged account, according to Plaintiff’s account summary (pg. 14 of your affidavit pdf) lists account inception as occurring 10/1/2006.
 
  c. Plaintiff is providing as court record and presenting as evidence of an account stated an account agreement that is four years outdated and one that defendant was never a party to.
 
  d. Plaintiff has misrepresented MATERIAL FACT in this legal matter. (Show misconduct!!)
 
3. It has been further brought to the Defendants attention per recent documents received on August 21st 2013 from Plaintiff that the state of issue for this alleged account is listed as Delaware……
 
 
 
(Not right. You’re making a giant leap here by not laying foundation as to why this is so…..it’s because Plaintiff has presented an account agreement that existed 4 years BEFORE your account ever came into existence, Plaintiff has provided inaccurate information. Because Plaintiff has presented inaccurate information, he hasn’t provided proof that your account 4 years later is still bound by Utah law, as a 4 yr. out-dated account agreement indicates. Because cc agreements are CONSTANTLY CHANGING THROUGH AMENDMENTS, no proof that this account is bound by Utah law.
 
 
 
4. We know that CIT online bank’s parent company, The CIT Group, is ORGANIZED in Delaware, and as a financial institution, is bound by Delaware banking laws. Delaware banking laws have a 3 yr, statute of limitations (cite the Delaware law that I provided at length from before)
 
 
 
5. Since Plaintiff has failed to provide any accurate account agreement that was in effect at the time of defendant’s alleged account, Delaware banking law prevails in this matter.
 
 
 
6. As such, Plaintiff is pursuing a time barred account per statute of limitations on both written and oral contracts in Delaware(Add:<comma> and per Delaware Law) is barred at three years .
 
 
 
7. As Plaintiff was aware of state of issue……(I don’t think Johnson Mark is aware of this…I would delete this and instead replace with a re-write as in #8..
 
 
 
8. Plaintiff’s documentation presented as legal record is deceitful and misrepresentative. Plaintiff is in direct opposition of Federal Civil Procedure code 11 for willfully filing for improper purpose, such as to harass, (eliminate this huge gap in space as written here) cause (Add: s) (Add: an) unnecessary delay, or (Eliminate ‘or’, replace with ‘and has’) needlessly increase(Add: d) cost(Add: s) of litigation. The above paragraph will be followed by a formal complaint against Plaintiff and all counsel involved in the listed action.
 
 
 

 
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Here’s what I would correct:
 
 
 
1. second line  Defendant….(needs an apostrophe between T and S)  ** I'm not sure what you mean. I don't have an S?**
 
2. Its been further brought to the Defendant’s attention that:   **Are you saying this should replace paragraph 2 that I already have or in supplement?**
 
 
  a. Plaintiff has filed as legal record a purported credit agreement, discovered by it’s facsimile time-stamp as having been transferred on 9/4/2002.
 
  b. Defendant’s alleged account, according to Plaintiff’s account summary (pg. 14 of your affidavit pdf) lists account inception as occurring 10/1/2006.
 
  c. Plaintiff is providing as court record and presenting as evidence of an account stated an account agreement that is four years outdated and one that defendant was never a party to.
 
  d. Plaintiff has misrepresented MATERIAL FACT in this legal matter. (Show misconduct!!)
 
3. It has been further brought to the Defendants attention per recent documents received on August 21st 2013 from Plaintiff that the state of issue for this alleged account is listed as Delaware……
 
 
 
(Not right. You’re making a giant leap here by not laying foundation as to why this is so…..it’s because Plaintiff has presented an account agreement that existed 4 years BEFORE your account ever came into existence, Plaintiff has provided inaccurate information. Because Plaintiff has presented inaccurate information, he hasn’t provided proof that your account 4 years later is still bound by Utah law, as a 4 yr. out-dated account agreement indicates. Because cc agreements are CONSTANTLY CHANGING THROUGH AMENDMENTS, no proof that this account is bound by Utah law.
 
 
 
4. We know that CIT online bank’s parent company, The CIT Group, is ORGANIZED in Delaware, and as a financial institution, is bound by Delaware banking laws. Delaware banking laws have a 3 yr, statute of limitations (cite the Delaware law that I provided at length from before)
 
 
 
5. Since Plaintiff has failed to provide any accurate account agreement that was in effect at the time of defendant’s alleged account, Delaware banking law prevails in this matter.
 
 
 
6. As such, Plaintiff is pursuing a time barred account per statute of limitations on both written and oral contracts in Delaware(Add:<comma> and per Delaware Law) is barred at three years .
 
 
 
7. As Plaintiff was aware of state of issue……(I don’t think Johnson Mark is aware of this…I would delete this and instead replace with a re-write as in #8..
 
 
 
8. Plaintiff’s documentation presented as legal record is deceitful and misrepresentative. Plaintiff is in direct opposition of Federal Civil Procedure code 11 for willfully filing for improper purpose, such as to harass, (eliminate this huge gap in space as written here) cause (Add: s) (Add: an) unnecessary delay, or (Eliminate ‘or’, replace with ‘and has’) needlessly increase(Add: d) cost(Add: s) of litigation. The above paragraph will be followed by a formal complaint against Plaintiff and all counsel involved in the listed action.  **I copied the rule from the Federal civil procedure. I'm not sure if I should change their wording**
 
 
 

 

 

 

I've included my questions directly in quote

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That's fine. Also, correction to #8-As such, Plaintiff is suing on a time-barred debt. Plaintiff’s documentation presented as legal record is deceitful and misrepresentative. Plaintiff lacks legal standing and is in direct opposition of Federal Civil Procedure code 11 for willfully filing for improper purpose, such as to harass, (eliminate this huge gap in space as written here) cause (Add: s) (Add: an) unnecessary delay, or....

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1.I'm not sure what you mean. I don't have an S?** Apostrophe is this ' Defendant's

2. No

Also, make my FDIC link I provided in an earlier post into a printed doc and provide it as Exhibit A with whatever motion your filing, and make reference to it's existence by;

4.Because no current banking law is available, we know that CIT online bank’s parent company, The CIT Group, is organized in Delaware (Exhibit A), and as a financial institution, is bound by Delaware banking laws. Delaware banking laws have a 3 yr, statute of limitations (cite the Delaware law that I provided at length from before)

Gotta go. I'm late for a jury research project I'm invited to at Emory Law School. I'll respond after 9 pm EST.

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Whatever you want to do, in the end this is your case. But I agree, I wasn't aware you were filing both. Regarding your SOL-you'll have to go into extreme detail. You're laying 'foundation'. Its a lot like 'if P then Q'...if this is true then this is true also. You'll have to connect the dots for them and how a four year old account agreement that doesn't pertain to your case cannot demonstrate which SOL state's SOL law this item falls under, and you'll have to include Delaware law in its entirety as I have, don't just 'mention' SOL. Mentioning it doesn't make it true. Provide facts. Demonstrate that Plaintiff's 2002 account Agreement can in no way determine anything.

 

Also I think you win by demonstrating that you were never given the entire contents of Plaintiff's purchasing agreement that the Bill of Sale is just one page of. Use Utah law on post #46 and include its entire definition that I provided. You get the judge's attention if you spell things out for them. They aren't going to be able to pull these laws off the top of their heads. Same with Federal Rule 11. State Plaintiff's wrong action then provide Federal Rule 11 and its written definition to why it relates. Also re-read post # 45 that I wrote to KentWa. Both of these items (skimpy docs provided and SOL) should win your case.

 

And here's this...

 

At no time has Plaintiff provided the court or Defendant with applicable credit agreement indicating any indication of state banking law in effect at the time of Defendant's alleged account tenure, thereby requiring the court to undertake this task. At specific issues is whether the contract may be amended at any time by the creditor, and the possibility that amendments to this agreement are frequent and very likely to have occurred in the four years after 2002. We know that the creditor CIT Bank Online's parent group, The CIT Group, is organized under the State of Delaware, and with no other likely indication, notice must be taken of Delaware's SOL law of three years that governed this account. As such, Plaintiff is attempting to collect on a time-barred debt.

 

The Utah statute controlling the change of terms of open-end consumer credit contracts (Utah Code Ann § 70C-4-102) provides:

"(2) (a) . . . a creditor may change any written term of an open-end consumer credit contract at any time while the open-end consumer credit contract is in effect and apply the new term to the unpaid balance in the account if:

"(i) the creditor mails or delivers written notice of the change . . . and

"(ii) the open-end consumer credit contract expressly provides that the creditor may change terms of the open-end consumer credit contract from time to time .

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State of Utah apply to and govern this agreement and your use of your account.

The credit agreement has an arbitration provision Jams-AAA-NAF.

You are being sued by Midland Funding (JDB) on a defaulted CIT Bank account.

Cit Bank is a state chartered bank in Utah NOT DELAWARE.

You might work on a different defense the Delaware Code Title 10, Chapter 81, § 8106 will not apply.

Learn the Utah rules of evidence.

http://www.utcourts.gov/resources/rules/urcp/ URCP

http://www.creditinfocenter.com/community/topic/312714-standing-when-dealing-with-jdb/ standing

 

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Except Plaintiff is trying to sue based on a credit agreement and terms Defendant was never a party to. Plaintiff provided terms that were in effect seven years before Defendant's alleged charge-off date, and due to the passage of significant time, Plaintiff cannot prove exactly under what banking law this alleged account was governed by.

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Rule 44. Proof of official record.

(d) Certified copy of record read in evidence. A copy of any official record, or entry therein, in the custody of a public officer of this state, or of the United States, certified by the officer having custody thereof, to be a full, true and correct copy of the original in his custody, may be read in evidence in an action or proceeding in the courts of this state, in like manner and with like effect as the original could be if produced.

(e) Official record defined. As used in this rule "official record" shall mean all public writings, including laws, judicial records, all official documents, and public records of private writings.

(f) Proof of the law of another state, territory or foreign country. A printed copy of a statute, or other written law of another state, or of a territory, or of a foreign country, or a printed copy of a proclamation, edict, decree or ordinance by the executive power thereof, contained in a book or publication purporting or proved to have been published by the authority thereof, or proved to be commonly admitted as evidence of the existing law of the judicial tribunals thereof, is presumptive evidence of the statute, law, proclamation, edict, decree or ordinance. The unwritten or common law of another state, or of a territory, or of a foreign country, may be proved as a fact by oral evidence. The books of reports of cases adjudged in the courts thereof must also be admitted as presumptive evidence of the unwritten or common law thereof. The law of such state or territory or foreign country is to be determined by the court or master and included in the findings of the court or master or instructions to the jury, as the case may be. Such finding or instruction is subject to review. In determining such law, neither the trial court nor the Supreme Court shall be limited to the evidence produced on the trial by the parties, but may consult any of the written authorities above named in this subdivision, with the same force and effect as if the same had been admitted in evidence.


Rule 44 d. No copy or original credit agreement in the custody of a public officer certified by the officer having custody thereof, is a full, true or correct copy bearing relevance in this action. A 2002 credit agreement presented as governing the terms of an account charged-off in 2009 cannot, by any stretch of the imagination, and in light of the dynamic nature of credit agreements, be in any way a full, true or correct copy.

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Rule 11. Signing of pleadings, motions, affidavits, and other papers; representations to court; sanctions.

 

b. Representations to court. By presenting a pleading, written motion, or other paper to the court (whether by signing, filing, submitting, or advocating), an attorney or unrepresented party is certifying that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances,

 

 

 

((1) it is not being presented for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation;

((2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for the extension, modification, or reversal of existing law or the establishment of new law;

((3) the allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery; and

((4) the denials of factual contentions are warranted on the evidence or, if specifically so identified, are reasonably based on a lack of information or belief.

 

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

 

Rule 11, b.4: Any critically-thinking attorney, certifying to the best of the person’s knowledge, information and belief, formed after an inquiry reasonable under the circumstances, and attempting to sue as a third-party, must recognize as inappropriate that a 2002 credit agreement is an out-dated, non-reliable, questionable representation and without any evidentiary support, to accurately represent an absent 2009 credit agreement between original parties.

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I want to preface this with the fact that I'm pretty sick and my brain is definitely not working in proper order. I was hoping to get my objection to the sanction mailed out tonight. I might not be able to send it certified mail unfortunately like I have everything else since the post office is closed by the time I get off but I think it's best that I get it out asap! Do you mind putting your thoughts in the order that I should add to the document I created? I really appreciate all of your help!!! I was thinking I would then do an objection to the affidavits and bill of sale. Finish off with a motion to dismiss just to cover all of my bases

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Your job is to show NO enforceable contract exists between the parties.

 

A credit card agreement is defined as "an agreement by a financial institution to lend,

delay, or otherwise modify an obligation to repay money, goods, or things in action,

otherwise extend credit, or make any other financial accommodation." Utah Code Ann.

§25-5-4 (2). As such, a credit card agreement is void unless the agreement, or some

memorandum thereof, is in writing. Utah Code Ann. §25-5-4 (1). Notwithstanding,

under Utah's Statute of Frauds, a written credit card agreement is binding and enforceable

without any signature, provided that:

the debtor is provided with a written copy of the terms of the agreement;

the agreement provides that any use of the credit offered shall constitute

acceptance of those terms; and after the debtor receives the agreement, the

debtor, or a person authorized by the debtor, requests funds pursuant to the

credit agreement or otherwise uses the credit offered.

Utah Code Ann. §25-5-4 (2)(e)(emphasis added).

 

Enforcement of a credit card agreement under the Statute of Frauds was addressed by the Utah Court of Appeals in Wells Fargo Bank v. Toronto, 2008 UT App 269.

Wells Fargo testified that it was the normal business practice when issuing a

new credit card to include a copy of the customer terms with the credit card. ld. at ~4.

The trial court was convinced defendants did receive the terms of the agreement and the

credit card, thereby creating an enforceable contract and the Court of Appeals upheld this

finding. Id

 

Use the plaintiffs evidence against him.(the 2002 credit agreement)

 

 

 

 

 

 

 

 

 

 

 

 

 

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I made a stupid mistake and now I really need some help. With help from a member of this site I was able to file an objection to the request for decision back in September, however I never heard anything back. On Jan 4th I was sent a request for decision that looked exactly like the one from September so I thought it was a duplicate of some kind. Now I've received a letter stating that because I didn't respond to the 2nd request they have now gotten an order signed to have my entry changed to default and are now pursuing a summary judgement. I don't know what to do.

 

I now have no internet access (using a friends computer).   I don't understand why they are pursuing this so hard, it now has been nearly a year and a half since they filed and I don't know how they can just keep filing requests for decisions with me having to reply multiple times. Is this legal????

 

 

Please let me know what I can do. Obviously I made a mistake but I can't pay the 3,200 they say I owe. I REALLY don't want them to win. 

 

Thank you.

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