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Yet another JDB complaint in Arizona


ulquiora
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1. Who is the named plaintiff in the suit? Some JDB

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Leaving out the name, but I checked and it is a real law firm, not just a PO Box.

3. How much are you being sued for? Just under $3500 + interest and legal fees

4. Who is the original creditor? (if not the Plaintiff) A major bank.

5. How do you know you are being sued? (You were served, right?) Served

6. How were you served? (Mail, In person, Notice on door) In person, at my home

7. Was the service legal as required by your state? Yes

8. What was your correspondence (if any) with the people suing you before you think you were being sued? None

9. What state and county do you live in? AZ, Cochise

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) According to collection notice on my credit report, the first default on the alleged debt occured in April 2009. I have no other records and the complaint provided no information other than alleged balance.

11. What is the SOL on the debt? 7 Years

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or    B) looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Summons Issued as of 11/5/13. I was served on 12/18/13.

13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No

14. Did you request debt validation before the suit was filed? No. I didn't know about it until I was served.

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? I have to answer by 1/7/2014. The charges are vague, but I'm assuming it hinges on "breach of contract."

16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. Full complaint is below.

 

--------------------------------
For its causes and complaint against the above named Defendant(s), the Plaintiff alleges as follows:

 

I

That Plaintiff is a legal entity entitled to bring this action under the Statutes of the State of Arizona. That Defendant(s) are residents of the State of Arizona. That Defendant(s), if applicable, are husband and wife, and the acts alleged herein were done for and on behalf of their marital community. Jurisdiction and venue are proper within COCHISE County and this Court.

 

II

That on or about **/**/2008, the Defendant(s) made, executed and delivered to {Bank Name}, a revolving Credit Account Application (Agreement). Thereafter, a contract was formed. The contract was subsequently sold and/or assigned by the original creditor to Plaintiff.

 

III

That Defendant(s) have breached such contract and defaulted in payment of the indebtedness owed to Plaintiff under the terms of the contract in the present principal sum of $xxxx, with accrued interest in the present sum of $xxxx, and with accruing interest at the contractual rate of x.xx percent per annum from date of judgment, until paid, after deducting all payments and just credits.

 

IV

That Plaintiff has made a demand upon Defendant(s) for payment of all sums due pursuant to the contract, but Defendant(s) have failed and refused to pay the amount.

 

V

Pursuant to the express written provisions in the contract, Plaintiff is entitled to recover from all of the Defendant(s) its reasonable attorney's fees and costs incurred in the prosecution of this action, and the collection of any judgment rendered. That Plaintiff alleges that the sum of $xxx is a reasonable sum to be allowed as and for its attorney's fees herein, in the event Judgment is rendered by default.

 

WHEREFORE, Plaintiff prays for judgment against Defendant(s), jointly and severally, as follows:

1. For the present principal sum of $xxxx;

2. For the accrued interest thereon in the present sum of $xxxx, plus accruing interest on the principal at the rate of X.XX% per annum from date of judgment, until paid;

3. For Plaintiff's reasonable prejudment and postjudgment attorneys' fees and costs incurred in the prosecution of this action, and the collection of any judgment rendered;

4. For such other and further relief as this Court may deem just and proper.

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

 

So...

 

Arizona, from what I've read, is a tough place to fight these vultures... and after checking my credit report... it seems I actually have a handful of "open" accounts by several JDBs who are also going to be suing me in the near future.

 

Win or lose, this could end up being a life-long battle of shooting down a case, having the account resold, and having to fight it again.

 

And if it was just me, I might even enjoy fighting back just for the fun of it.

 

However, I'm recently married and my wife has nothing to do with any of these debts.

 

And since this is Arizona, I don't think any judge will treat her fairly if things don't go well for me in trying to fight off all the JDBs by myself.

 

I'm starting to think I may be better off just planning on filing Chapter 7 to save my wife from any future hardships.

 

If anyone here is, or can recommend, an attorney experienced enough to successfully defend this particular case, please PM me to discuss retainer.

 

Otherwise, any conversational insights into a hypothetical defense for the case are also welcome.

 

Thanks.

Edited by ulquiora
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@ulquiora

 

1. Who is the named plaintiff in the suit? Me

 

 

You are the defendant (the one who must defend himself).  The one who is suing you is the plaintiff.

 

 

That on or about **/**/2008, the Defendant(s) made, executed and delivered to {Bank Name}, a revolving Credit Account Application (Agreement). Thereafter, a contract was formed. The contract was subsequently sold and/or assigned by the original creditor to Plaintiff.

 

 

I'm assuming that this is, in fact, your debt.  Did you fill out and sign an application?  

 

When it's time to request discovery, I'd be requesting the application that they claim you "made, executed, and delivered".  The same for #5 (V).

 

Anyway, did they include any evidence, such as billing statements, with the summons and complaint?  If they didn't include any evidence at all, you might be able to simply deny all of the allegations except for #1.

 

Read your court rules of civil procedure to see if you have to include an explanation with a denial.  There's a number of AZ residents here on the boards who'll help you.  

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check the rules on community property, if you incurred the debt before you were married, and defaulted on before, they cannot hold her responsible. (check our rules, but I believe that is what it said for AZ).  If they filed against her, she should be able to answer her part with a motion to dismiss based on the date of your marriage, maybe a copy of your marriage licence as proof thereof.

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You are the defendant (the one who must defend himself).  The one who is suing you is the plaintiff.

 

Wow, yeah, totally misread the question. The plaintiff is of course the JDB.

 

As for the signature, every card I've ever applied for was an online application with a "type your name here to sign" type form.

 

And no, they included no evidence whatsoever with the complaint.

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...

8. What was your correspondence (if any) with the people suing you before you think you were being sued? None

...

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) According to collection notice on my credit report, the first default on the alleged debt occured in April 2009. I have no other records and the complaint provided no information other than alleged balance.

11. What is the SOL on the debt? 7 Years

...

14. Did you request debt validation before the suit was filed? No. I didn't know about it until I was served.

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? I have to answer by 1/7/2014. The charges are vague, but I'm assuming it hinges on "breach of contract.

...

I

That Plaintiff is a legal entity entitled to bring this action under the Statutes of the State of Arizona. That Defendant(s) are residents of the State of Arizona. That Defendant(s), if applicable, are husband and wife, and the acts alleged herein were done for and on behalf of their marital community. Jurisdiction and venue are proper within COCHISE County and this Court.

...

IV

That Plaintiff has made a demand upon Defendant(s) for payment of all sums due pursuant to the contract, but Defendant(s) have failed and refused to pay the amount.

...

WHEREFORE, Plaintiff prays for judgment against Defendant(s), jointly and severally, as follows:

...

3. For Plaintiff's reasonable prejudment and postjudgment attorneys' fees and costs incurred in the prosecution of this action, and the collection of any judgment rendered;

...

However, I'm recently married and my wife has nothing to do with any of these debts.

 

And since this is Arizona, I don't think any judge will treat her fairly if things don't go well for me in trying to fight off all the JDBs by myself.

...

Answer 8 & 14 contradict complaint paragraph IV and would appear to show opposing to be liars. No shock there IMO.

Answer 10 and recently married would indicate a need to look into AZ community property case law. (see below). I am assuming the spouse is being sued (named as defendant) thus causing the concern stated by the OP.

Answer 11 sates SOL is 7 years. I am unfamiliar with that. I understand SOL on CC debt to be 6 years in AZ.

In item 3 in the prayer for relief there is no statute or contract cited as justification for attorney fees. AFAIK you have to have some justification to present to the court if you want the loser to pay and to do some fee shifting overriding the American Rule on attorney fees.

 
The governing AZ statute on community property liability appears to be: A.R.S. 25-215. Liability of community property and separate property for community and separate debts
 
"As a general proposition, we agree that a creditor cannot reach marital community property to satisfy a separate obligation incurred by either spouse after marriage." citing Schilling v. Embree, 575 P.2d 1262, 118 Ariz. 236 (Ct. App. 1977).

 

Chapter 7 BK is pretty extreme IMHO. I would determine if it made sense to fight the JDBs and upon any adverse judgment fall back on the BK "nuclear" option. To keep the peace at home I would seriously consider consulting an attorney if I had similar concerns and my spouse was listed as a defendant.

 

A judge has no choice in how they treat someone unless we let them. They must follow the law and not run rogue over what the legislature and stare decisis have decided. Arizona is not consumer friendly, as the legislature has made clear in their legislating, but posters here have defeated JDBs that chose to sue them on alleged debt.

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check the rules on community property, if you incurred the debt before you were married, and defaulted on before, they cannot hold her responsible. (check our rules, but I believe that is what it said for AZ).  If they filed against her, she should be able to answer her part with a motion to dismiss based on the date of your marriage, maybe a copy of your marriage licence as proof thereof.

 

I would agree with this approach. If you are newly married but you are both being sued, I believe she can file a motion to dismiss as her "answer". AZ is a community property state, but debts prior to marriage are not then owed by both when you get married. I have looked for case law on this myself but I'm not good at finding that stuff, yet. I have a similar situation.

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@ulquiora I'm pretty sure I know who the JDB is, as well as the OC (bank) and the law firm handling this case.  If I'm right, a read through my thread will give you an idea of what lies in store for you.

 

http://www.creditinfocenter.com/community/topic/321144-sued-by-jdb-cavalry-in-arizona/

 

If I'm right about the OC, they are headquartered in Delaware and the credit card agreement demands Delaware law govern the agreement.  Ready for the kicker?  Delaware SOL on all debts (including credit cards) is 3 years.  You can see how I handled this in my thread.  I have not had an opportunity to argue this at trial yet, but when you file your answer, you absolutely need to include as an affirmative defense the Statute of Limitations.  Also, since you are being sued by someone other than the alleged creditor, you need to claim Lack of Standing as an affirmative defense.

 

 

As a side note, I think you should also take the approach that Arizona SOL at the time you allegedly obtained the card and allegedly defaulted was 3 years.  Also covered in my thread.  I would expect this to fall flat, but I wouldn't let the opportunity to have it heard by the court pass you by.

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Ok guys legal writing 101

 

Judges prefer answers, complaints, and pleadings to be in plain English. They actually think that lawyers, and pro se,  who use legalese have less prestige, are less smart, and are ranked academically lower, and are trying to show off.

Write in active voice not passive, active means use your last name.  In stead of going through and answering each complaint one at a time simply state, Defendant (your last name) answers the complaint as follows.

for every sentence in the complaint that you admit say it in one line, Defendant (name) denies(or admits) all paragraphs of the complaint except as listed below.

So we would have as an example, let say your last name is Edwards

Defendant, Edwards, denies all paragraphs of plaintiffs complaint. Or if you are admitting to some but not all,

Defendant, Edwards, denies all paragraphs of the complaint except as listed below

Edwards admits to paragraphs, 1,3,5,6

If a paragraph is half ttrue and you want to admit in part and deny in part

Edwards admits to paragraph 2 in part but denies (blah blah blah.)

 

so lets say the complaint goes something like plaintiff alleges that defendant, Edwards,  obtained a credit card and and now owes the plaintiff 5000 dollars

Answer like this

Defendant, Edwards admits that he obtained a credit card but denies that he owes the plaintiff any sum of monies. You do not have to go into to great detail, that will be done at the trial. I was taught in my advanced legal writing class that I am now taking, KISS keep it simple stupid.

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Ok guys legal writing 101

 

Judges prefer answers, complaints, and pleadings to be in plain English. They actually think that lawyers, and pro se,  who use legalese have less prestige, are less smart, and are ranked academically lower, and are trying to show off.

Write in active voice not passive, active means use your last name.

...

Could you clarify if this is in response to the language used in the plaintiff's "Full complaint" presented in post #1 or something else?

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Write in active voice not passive, active means use your last name.

 

 

That is not the definition of "active voice".  It simply means to connect the subject with the action. 

 

Passive

 

The motion was filed by the plaintiff.

 

The action is the filing.  Who did the filing?  The plaintiff.

 

Active

 

The plaintiff filed the motion.  

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That is not the definition of "active voice".  It simply means to connect the subject with the action. 

 

Passive

 

The motion was filed by the plaintiff.

 

The action is the filing.  Who did the filing?  The plaintiff.

 

Active

 

The plaintiff filed the motion.  

In active voice the subject is doing the action, David loves Angie.  In passive the target of the action gets promoted to the subject position,,,,,Angie is loved by David 

Could you clarify if this is in response to the language used in the plaintiff's "Full complaint" presented in post #1 or something else?

Everyone on this board should buy and read Making your case, the art of persuading the judge, I have it and we review it in class daily,, it was written by Bryan Garner and co authored by Justice Scalia, It won best legal book for the year. Time and time again Justice Scalia says write in plain English.  The days of comes now the defendant, blah blah blah are gone.

Judges would rather read a short precise to the point pleading or answer than have to sit and read 20 pages. I am trying to help everyone make their answers so much easier than all this long winded stuff, I used to do it, until I started studying exactly how legal pleading should be done. I had judges tell me several times to fix it. 

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In active voice the subject is doing the action, David loves Angie.  In passive the target of the action gets promoted to the subject position,,,,,Angie is loved by David

 

 

The above is correct.  That is not how you previously explained it.  It has nothing to do with adding your last name after the word "defendant".

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If I'm right about the OC, they are headquartered in Delaware and the credit card agreement demands Delaware law govern the agreement.  Ready for the kicker?  Delaware SOL on all debts (including credit cards) is 3 years.  You can see how I handled this in my thread.  I have not had an opportunity to argue this at trial yet, but when you file your answer, you absolutely need to include as an affirmative defense the Statute of Limitations.  Also, since you are being sued by someone other than the alleged creditor, you need to claim Lack of Standing as an affirmative defense.

 

The court provides these little fill-in-the-blank response forms, and the motion form has two blanks to fill in.

 

1. This motion is to ask the Court to: _________

2. for the following reasons: _____________

 

So shouldn't it be enough to just give a hand-written, plain english answer on one of those forms to the effect of:

 

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

1. Dismiss with prejudice

2. {OC's} credit card agreement states: "This Agreement is made in Delaware and we extend credit to you from Delaware. This Agreement is governed by the laws of the State of Delaware (without regard to its conflict of laws principles) and by any applicable federal laws."

 

And since Delaware law places a 3 year statute of limitations on collection of this debt, the plaintiff's complaint is time barred.

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

 

The end?

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The court provides these little fill-in-the-blank response forms, and the motion form has two blanks to fill in.

 

1. This motion is to ask the Court to: _________

2. for the following reasons: _____________

 

So shouldn't it be enough to just give a hand-written, plain english answer on one of those forms to the effect of:

 

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

1. Dismiss with prejudice

2. {OC's} credit card agreement states: "This Agreement is made in Delaware and we extend credit to you from Delaware. This Agreement is governed by the laws of the State of Delaware (without regard to its conflict of laws principles) and by any applicable federal laws."

 

And since Delaware law places a 3 year statute of limitations on collection of this debt, the plaintiff's complaint is time barred.

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

 

The end?

 

Yes, if you lived in Delaware throughout the life of the account, applied for the card from Delaware and used the card exclusively in Delaware it would be this simple.  The complexity comes from the fact that you allegedly live(d) in Arizona, allegedly requested the card from the State of Arizona and allegedly used it to make purchases from the State of Arizona and opposing will exploit this to the fullest extent.  Since I have gone down this road with them already, you can know how they will respond and counter their arguments before they even make them.  Of course they will push on through and/or find some other angle, but at least you will be able to force them to reach a little harder for it.  And they will immediately know you've seen their bag of tricks which could make them a little less interested in pursuing this.

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Hey, couple more things....  When they serve you with Initial Disclosure, you will get a copy of a "Bill of Sale" which will say:

"The undersigned Assignor ("Assignor'') on and as of the date hereof hereby absolutely sells, transfers, assigns, sets-over, quitclaims and conveys to [JDB], a limited liability company organized under the laws of Delaware ("Assignee") without recourse and without representations or warranties of any type, kind, character or nature, express or implied".

 

This is saying that the "Bank" is refusing to guarantee the accuracy of the data included with the sale.  If the Bank will not guarantee the accuracy, how on earth can the JDB guarantee it is accurate?

 

Also, there will be nothing at all provided to you certifying the Bill of Sale.  It will be signed by an officer of the "Bank", but JDB will present nothing (no affidavit, etc) that proves this individual is a real person, that the Bill of Sale is genuine or that the signor is even legally entitled to authorize such a sale.  The Bill of Sale isn't worth the paper it's printed on.

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The court provides these little fill-in-the-blank response forms, and the motion form has two blanks to fill in.

 

1. This motion is to ask the Court to: _________

2. for the following reasons: _____________

 

So shouldn't it be enough to just give a hand-written, plain english answer on one of those forms to the effect of:

 

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

1. Dismiss with prejudice

2. {OC's} credit card agreement states: "This Agreement is made in Delaware and we extend credit to you from Delaware. This Agreement is governed by the laws of the State of Delaware (without regard to its conflict of laws principles) and by any applicable federal laws."

 

And since Delaware law places a 3 year statute of limitations on collection of this debt, the plaintiff's complaint is time barred.

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

 

The end?

You should also state that the complaint is based on an alleged contract, which the plaintiff has failed to provide as evidence. Since they use the term contract, an application or credit card holder agreement will not suffice. When I claim is made on a contract the contract governs and needs to be produced.

Never argue your case on just one affirmative defense, if that fails you need another angle or several to attack the complaint. I go for broke and show why the complaint for for every reason I can come up with. Do you ever see a complaint against the defendant based on one theory of law. You also need to remember than any complaint not rebutted is considered true, so rebut every thing they complain of.

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You should also state that the complaint is based on an alleged contract, which the plaintiff has failed to provide as evidence. Since they use the term contract, an application or credit card holder agreement will not suffice. When I claim is made on a contract the contract governs and needs to be produced.

Never argue your case on just one affirmative defense, if that fails you need another angle or several to attack the complaint. I go for broke and show why the complaint for for every reason I can come up with. Do you ever see a complaint against the defendant based on one theory of law. You also need to remember than any complaint not rebutted is considered true, so rebut every thing they complain of.

I was also going to touch on the bill of sale but Harry covered that pretty good.

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Never argue your case on just one affirmative defense, if that fails you need another angle or several to attack the complaint. I go for broke and show why the complaint for for every reason I can come up with. Do you ever see a complaint against the defendant based on one theory of law. You also need to remember than any complaint not rebutted is considered true, so rebut every thing they complain of.

 

Yes, everything you say is true for the answer. But this is a pre-emptive MTD. If the judge denies it, I still have 10 days to submit a full answer. Or did I misunderstand the AZ rules for civil procedure?

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@BTO429

 

You should also state that the complaint is based on an alleged contract, which the plaintiff has failed to provide as evidence. Since they use the term contract, an application or credit card holder agreement will not suffice. When I claim is made on a contract the contract governs and needs to be produced.

 

 

Incorrect.  The only documents for a credit card account would be an application and/or the cardmember agreement.  There is no other document that would serve as a contract.

 

Since the complaint referenced an application, that is what should be produced.

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@BTO429

 

Incorrect.  The only documents for a credit card account would be an application and/or the cardmember agreement.  There is no other document that would serve as a contract.

 

Since the complaint referenced an application, that is what should be produced.

Of course it must be of the same class of CC agreements that actually would have applied to the alleged debtor.

 

I believe someone posted on the forum recently the name of a separate supplemental agreement that some banks use to provide interest rate terms. When that is the situation it would seem that the ability to charge interest might rely on that secondary agreement. Charging interest above the state legal limit without an agreement providing for such a rate is often seen as usury.

 

Applications have specific terms. Often these terms include arbitration (with or without survivability), choice of law, etc. A generic application, not proven to be the exact terms that could bind a defendant, might mean that the plaintiff may be wishing to apply different terms that may be more beneficial to them. One would hope that something like a statute of frauds (and court enforcement of same) would tend to prevent such monkey business.

 

Since OCs struggle to present admissible evidence that would prove that a specific contract actually binds a defendant I almost feel sorry for downstream JDBs attempting to prove that specific terms apply to a specific defendant and that they can prove that they have legally stepped into the shoes of the contract originator. Since the courts routinely ignore the facts and the law to the detriment of consumer defendants I don't feel anything approaching sorry for the JDB's purchasing a line entry on a spreadsheet for 5 cents on the dollar.

 

JDBs suing on the basis of a 5% purchase price, while knowing they lack admissible evidence to prove up their claims, probably should be treated as vexatious litigants by the courts. I am confident I would be treated as such if I continuously filed unprovable claims with the court.

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@Credator

 

Of course it must be of the same class of CC agreements that actually would have applied to the alleged debtor.

 

 

 

I was merely referring to BTO's response.  What do you mean by "the same class"?

 

With a credit card account, you have an application (sometimes, not always) and a cardmember agreement.  That's it...nothing else.

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@BV80

@Credator

 

 

I was merely referring to BTO's response.  What do you mean by "the same class"?

 

With a credit card account, you have an application (sometimes, not always) and a cardmember agreement.  That's it...nothing else.

I would understand "class of credit cards" (likely to have differing terms) to include such things as VISA Classic, gold cards, platinum cards, airline miles reward cards, etc. I would not feel comfortable letting a plaintiff's claim stand that a generic card agreement applies when I never had a generic card agreement with said plaintiff.

 

I would view a separate document containing part of the CC agreement (such as a "card carrier") as fairly significant, especially if AWOL in a collection lawsuit.

 

Here is a recent (Rev. 6/2013) CC agreement that contains the terms spread over two different documents: http://www.regions.com/virtualdocuments/Visa_Credit_Card_Agreement.pdf

This document, together with the “Account Summary Table” on the accompanying card carrier, form the “Agreement” that governs the credit card account established for you by Regions Bank (“Account”) and each Visa credit card issued to access the Account (a “Card”).

 

I recall the post I referenced in this thread as being specific about certain banks using more than just a single document for their CC agreements and therefore it seemed to have enough credibility that *I* would want to research the issue thoroughly before completely discounting it in my specific situation.

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"The undersigned Assignor ("Assignor'') on and as of the date hereof hereby absolutely sells, transfers, assigns, sets-over, quitclaims and conveys to [JDB], a limited liability company organized under the laws of Delaware ("Assignee") without recourse and without representations or warranties of any type, kind, character or nature, express or implied".

 

This is saying that the "Bank" is refusing to guarantee the accuracy of the data included with the sale.  If the Bank will not guarantee the accuracy, how on earth can the JDB guarantee it is accurate?

 

 

YES!  That was one of my points in a case but was ignored and lost on MSJ by JDB in Justice Court. However, won in Superior Court on appeal  a remand and reversal on many points but this one not mentioned, although I did...
 
This would seem to be a strong argument. 
 
I have not caught up will all the great wisdom in the last year since I was more following here... haven't made it thru Harry's great thread yet... but wow lots of great info related to our Maricopa Cty cases and all the slam dunk losses it seems in Justice Courts.
 
I think perhaps some of us have the same JDB since wording seems the same. Starts with a "C"?
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