GinnyCoonrod

Help Midland Funding is trying to be really sneaky but I am not sure what they are up to.

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Who is the named plaintiff in the suit?

 

Midland Funding, LLC.

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Stelios A. Harris, Karen E. Lusis, Mishaela J Graves, Timothy Brown, Sarah A Robinson-McElroy

 

3. How much are you being sued for?

 

2013.01

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

 

HSBC Bank.

5. How do you know you are being sued?

 

I received a letter from LegalWing telling me I was being sued and they wanted to help me. Then I got another letter a few weeks later from a different legal group Country-wide Debt Relief.

 

I did a search on the Superior Court website and I found the lawsuit. April 17, 2014. I downloaded it which cost 30.00. ouch  I read it and waited but I was never served. On May 1, 2014 I checked the Court records and saw that I was served by substitute service on April the 8th at 7:50 PM. Summons was served on a gray-haired woman  60+ years old who was approx 5’7” 150 lbs. And refused to give her name Then he allegedly placed a copy of the paperwork in the mail with First Class Postage . I never received anything. Other attempts he claims that he made were 7:32 AM on 3/27, 2:58 PM on 3/30, 6:19 PM on 4/02, 10:16 AM on 4/05, then the 4/8 attempt at 7:50 PM.

 

What they don’t know is I manage the Mobilehome Community  where I live and my office is looking right out at my house. There is no way anyone attempted to serve me papers especially that many times and I did not see them or one of my neighbor's did not see him. Oh they would have called me so fast. Not to mention you can't loiter or hang out in a car in our community. You would stick out . One of my residents would have reported it to me if I had missed it.

 

(You were served, right?)

 

6. How were you served? (Mail, In person, Notice on door) Sorry got ahead of the question

 

He said he left a marker on my door in the papers he filed in the court.. We never saw anything on our door.

 

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

Process Service Requirements by State - Summons Complaint

 No

8. What was your correspondence (if any) with the people suing you before you think you were being sued?

 

I believe I received one statement from them but I do not know what happened to it. I don’t have anything from Midland except a letter dated 4/16/2014 which I received after I printed out the Proof of Service of Summons on May 1st   (it was filed in the court record on 4/21/14) I have not talked to anyone.

 

9. What state and county do you live in?

 

Orange County, California- Court will be in Santa Ana

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations)

6/2011

 

11. What is the SOL on the debt? To find out: 

Statute of Limitations on Debts

 

The SOL for this debt is 4 years.

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or   looking it up online (many states have this information posted - when you find the online court site, search by case number or your name).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? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late.
 

NO.

15. How long do you have to respond to the suit?  I already did  (This should be in your paperwork). We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? Yes

 

 Account Stated- Just the Special Interrogatorries-I have responded to everything so far but I don’t like what is going on now.. I mean I believe with all my heart these people knew I was never served especially with the dates that they filed the service paperwork. When I answered the Complaint I did not have much time.

Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits

 

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

They did not attach anything. Not a single thing.

 

 

 

Complaint for: (1) Account Stated.

 

Following the complaint is the First Cause of Action:

 

- Plaintiff realleges and incorporates by reference the foregoing paragraphs.

 

- Within the last 4 years, Defendant became indebted on the Account to Plaintiff in the sum of  $2013.01 on an account stated in writing by and between Plaintiff and Defendant in which it was agreed that Defendant was indebted to Plaintiff. 

 

- Plaintiff has made demand on Defendant for repayment of the account stated but Defendant has failed and refused to pay the balance due.

 

- As of the date of this complaint, there is due and owing the unpaid sum of  $2013.01  Cost of suit and whatever the court deems just and proper less credits or adjustments of $0.00..

 

 

The status of my case is: Case Filed

I answered the summons May 8th with information I got from this website. I basically denied everything

 

They sent me Interrogatories, Admissions and Production of Doc’s.. I answered all of those with answers I found here. And sent them to them cmrrr

 

Next I sent them- Defendant’s first request for Production of documents. I sent those July 16, cmrrr

 

Midland sent me 1 Statement from Orchard Bank dated  12/12/2011

 

and a Assignment and Bill of Sale from HSBC to Bureau’s Investment Group III dated 1/20/2012

There is no reference to my name or the alleged account in question it states " this is a sale of Prime Fresh Charged off Receivables described in Paragraph one thereof   upon the terms and conditions set forth herein."

Then a little further on it says "for good and valuable consideration blah blah blah (pretty much word for word what I have read here) Purchase Price shall be as stated in Paragraph 3 of Agreement Attached

 

. No Attachments at all.

 

The Next document is an Assignment and Bill of Sale from Bureau’s Investment Group Portfolio No 15 LLC to Midland Funding that is dated on May 7 2013.

 

This document has a lot of redaction then talks about Purchased accounts File, The Chain of Title File,  and Seller’s Accounts information

 

Then on the last page it Says This Bill of Sale is Executed without recourse or warranties except as stated and provided for in the agreement.

 

Again "No Agreement"

 

A field data sheet with my name and info

 

It says Data Printed by Midland Funding from electronic records provided by Bureau's Investment Group Portfolio No.15  LLC pursuant to the Bill of Sale/Assignment of Accounts transferred on or about 5/8/2013 in connection with the sale of accounts  from Bureau's Investment Group Portfolio No. 15 LLC to Midland Funding.

 

Affidavit of Bulk Sale of Accounts all of this took place in Delaware by the way.

 

There is also Bureau’s Investment Group Certificate of Sole Member  a Michael Slotky

 

Some more junk then some statements they say they sent me which I have never seen.

 

They included in passing that they would send a verification of all the junk in a few days.

 

We have a Case Management Conference scheduled for August 5th.

 

I sent out a meet and confer cmrrr because I have issues with the fact that they have not shown me anything that says I owe them any money.

They do not have any paper with my name and/or the alleged account number on it except 1 Orchard Bank statement from 12/2011.

 

I don't think that piece of paper means squat . It does not show or prove that Midland owns that account.

 

They sent me a case management statement and it says that we completed Discovery however (they stated in the answers to me  that discovery was ongoing they were still reviewing)

 

I sent Midland Funding my case management statement yesterday and I am filing it with the court today.

 

 Then today I got this verification as to responses Leslie Armento an employee of Midland Funding LLC. She is the servicer of the account in question.

 

 

 

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So what didn't they give you in your requests for production? In your case management you need to say discovery is still ongoing and not complete if you file that.

Did you request the purchase agreement from original creditor to the 1st JDB?

If not I would send a 2nd request out for rfd's, and ask for it as referenced on the bill of sale dated xx xx xxxx from oc to JDB. Did they send you any bill of sales from the other JDB to JDB? Does it have the same reference of no warren it's? If so request those purchase agreements also.

Did they send an affidavit with each bill of sale with the language that says information was transmitted to xxxx by a person with knowledge of your account, and it is true and correct? (Can't say believed to be true, has to be true).

Your case should be fairly easy to beat if you play your cards right. More than one JDB will require testimony from each entity to prove your account was part of the sale, and it is correct. But you will have to object to each affidavit, so the court won't let it in to evidence.

Read the thread pinned at the top by astmedic's, and read the long thread by homelessinca. Both have valuable info, as well as examples of objections, what to do next. Come back with questions.

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 On May 1, 2014 I checked the Court records and saw that I was served by substitute service on April the 8th at 7:50 PM. Summons was served on a gray-haired woman  60+ years old who was approx 5’7” 150 lbs. And refused to give her name Then he allegedly placed a copy of the paperwork in the mail with First Class Postage . I never received anything. Other attempts he claims that he made were 7:32 AM on 3/27, 2:58 PM on 3/30, 6:19 PM on 4/02, 10:16 AM on 4/05, then the 4/8 attempt at 7:50 PM.

 

What they don’t know is I manage the Mobilehome Community  where I live and my office is looking right out at my house. There is no way anyone attempted to serve me papers especially that many times and I did not see them or one of my neighbor's did not see him. Oh they would have called me so fast. Not to mention you can't loiter or hang out in a car in our community. You would stick out . One of my residents would have reported it to me if I had missed it.

 

Consider asking the court for permission to amend your answer, to include a cross-complaint.  Probably a long-shot, but could be very helpful if the judge allows it.

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Then on the last page it Says This Bill of Sale is Executed without recourse or warranties except as stated and provided for in the agreement.

 

Again "No Agreement"

 

Nice.  You should request that agreement.

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Ginney,

 

Sounds like you are doing ok so far by following the information you have found here.  So here are a couple of pointers-

 

1.  Service of the complaint was likely not legal, but you have answered the suit and participated in discovery.  This would mean in the courts view you have not been prejudiced in any way, so this is a dead issue at this time.

 

2.  Case Management conference is where both sides update the court on where the case stands, from this point the judge will want to set a date for trial, most likely.

 

3.  Because you have stated this account was sold twice, once for OC to JDB 1 and then from JDB1 to Midland.  You will want to review CCP 2015.5 (B).  This rule of civil procedure explains what an out ot state affidavit needs to have in order for the court to consider it.  Only you can see if the affidavit from Delaware meets the code.  But this would be a big issue if it doesn't, and is the first nail in winning the case.  This could break the chain of title for the Bill of Sale, along with the other issues you have pointed out, no name, no account number, etc.

 

I would not mention this at the Case Management, it is for use at trial, an should surface in our trial brief and/or Motion in Limmine prior to trail.....

 

Best of Luck

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Judge X in Orange County is solidly Pro-Plaintiff. Should Midland choose to show up, they will have to prove very little to prevail.

Conversely, you will have to prove a great deal to avoid a judgement against you. Its backwards.

Take a mon-wed morning off to sit in on a trial date in your Dept at the Courthouse.

Afterwards you'll want to file a brief motion, along with one of these:

www.occourts.org/forms/local/l292.pdf

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Judge X in Orange County is solidly Pro-Plaintiff. Should Midland choose to show up, they will have to prove very little to prevail.

Conversely, you will have to prove a great deal to avoid a judgement against you. Its backwards.

Take a mon-wed morning off to sit in on a trial date in your Dept at the Courthouse.

Afterwards you'll want to file a brief motion, along with one of these:

www.occourts.org/forms/local/l292.pdf

I like this strategy. A lot. I would advise for any who draws my trial judge in San diego county as well. Maybe in order to ensure a fair trial, you have to take measures beforehand.

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When you go to court, try and have a court reporter handy to take notes and also object to anything that you think is not right or legal. This will help you set up for an appeal, and the fact that you have a court reporter on hand might make the judge a little more honest.

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So what didn't they give you in your requests for production? In your case management you need to say discovery is still ongoing and not complete if you file that.

Did you request the purchase agreement from original creditor to the 1st JDB?

If not I would send a 2nd request out for rfd's, and ask for it as referenced on the bill of sale dated xx xx xxxx from oc to JDB. Did they send you any bill of sales from the other JDB to JDB? Does it have the same reference of no warren it's? If so request those purchase agreements also.

Did they send an affidavit with each bill of sale with the language that says information was transmitted to xxxx by a person with knowledge of your account, and it is true and correct? (Can't say believed to be true, has to be true).

Your case should be fairly easy to beat if you play your cards right. More than one JDB will require testimony from each entity to prove your account was part of the sale, and it is correct. But you will have to object to each affidavit, so the court won't let it in to evidence.

Read the thread pinned at the top by astmedic's, and read the long thread by homelessinca. Both have valuable info, as well as examples of objections, what to do next. Come back with questions.

 

Will you please PM a copy of Affidavit of Bulk Sale of Accounts all of this took place in Delaware by the way.

 

I believe that Midland has a fresh batch of cases that they are filing throughout the southern California area.

 

 

Thanks.

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Who is the named plaintiff in the suit?

 

Midland Funding, LLC.

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Stelios A. Harris, Karen E. Lusis, Mishaela J Graves, Timothy Brown, Sarah A Robinson-McElroy

 

3. How much are you being sued for?

 

2013.01

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

 

HSBC Bank.

5. How do you know you are being sued?

 

I received a letter from LegalWing telling me I was being sued and they wanted to help me. Then I got another letter a few weeks later from a different legal group Country-wide Debt Relief.

 

I did a search on the Superior Court website and I found the lawsuit. April 17, 2014. I downloaded it which cost 30.00. ouch  I read it and waited but I was never served. On May 1, 2014 I checked the Court records and saw that I was served by substitute service on April the 8th at 7:50 PM. Summons was served on a gray-haired woman  60+ years old who was approx 5’7” 150 lbs. And refused to give her name Then he allegedly placed a copy of the paperwork in the mail with First Class Postage . I never received anything. Other attempts he claims that he made were 7:32 AM on 3/27, 2:58 PM on 3/30, 6:19 PM on 4/02, 10:16 AM on 4/05, then the 4/8 attempt at 7:50 PM.

 

What they don’t know is I manage the Mobilehome Community  where I live and my office is looking right out at my house. There is no way anyone attempted to serve me papers especially that many times and I did not see them or one of my neighbor's did not see him. Oh they would have called me so fast. Not to mention you can't loiter or hang out in a car in our community. You would stick out . One of my residents would have reported it to me if I had missed it.

 

(You were served, right?)

 

6. How were you served? (Mail, In person, Notice on door) Sorry got ahead of the question

 

He said he left a marker on my door in the papers he filed in the court.. We never saw anything on our door.

 

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

Process Service Requirements by State - Summons Complaint

 No

8. What was your correspondence (if any) with the people suing you before you think you were being sued?

 

I believe I received one statement from them but I do not know what happened to it. I don’t have anything from Midland except a letter dated 4/16/2014 which I received after I printed out the Proof of Service of Summons on May 1st   (it was filed in the court record on 4/21/14) I have not talked to anyone.

 

9. What state and county do you live in?

 

Orange County, California- Court will be in Santa Ana

10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations)

6/2011

 

11. What is the SOL on the debt? To find out: 

Statute of Limitations on Debts

 

The SOL for this debt is 4 years.

12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or   looking it up online (many states have this information posted - when you find the online court site, search by case number or your name).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? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late.

 

NO.

15. How long do you have to respond to the suit?  I already did  (This should be in your paperwork). We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? Yes

 

 Account Stated- Just the Special Interrogatorries-I have responded to everything so far but I don’t like what is going on now.. I mean I believe with all my heart these people knew I was never served especially with the dates that they filed the service paperwork. When I answered the Complaint I did not have much time.

Here is an example of what the summons/complaint may look like: Sued by a Debt Collector - Learn How to Fight Debt Lawsuits

 

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

They did not attach anything. Not a single thing.

 

 

 

Complaint for: (1) Account Stated.

 

Following the complaint is the First Cause of Action:

 

- Plaintiff realleges and incorporates by reference the foregoing paragraphs.

 

- Within the last 4 years, Defendant became indebted on the Account to Plaintiff in the sum of  $2013.01 on an account stated in writing by and between Plaintiff and Defendant in which it was agreed that Defendant was indebted to Plaintiff. 

 

- Plaintiff has made demand on Defendant for repayment of the account stated but Defendant has failed and refused to pay the balance due.

 

- As of the date of this complaint, there is due and owing the unpaid sum of  $2013.01  Cost of suit and whatever the court deems just and proper less credits or adjustments of $0.00..

 

 

The status of my case is: Case Filed

I answered the summons May 8th with information I got from this website. I basically denied everything

 

They sent me Interrogatories, Admissions and Production of Doc’s.. I answered all of those with answers I found here. And sent them to them cmrrr

 

Next I sent them- Defendant’s first request for Production of documents. I sent those July 16, cmrrr

 

Midland sent me 1 Statement from Orchard Bank dated  12/12/2011

 

and a Assignment and Bill of Sale from HSBC to Bureau’s Investment Group III dated 1/20/2012

There is no reference to my name or the alleged account in question it states " this is a sale of Prime Fresh Charged off Receivables described in Paragraph one thereof   upon the terms and conditions set forth herein."

Then a little further on it says "for good and valuable consideration blah blah blah (pretty much word for word what I have read here) Purchase Price shall be as stated in Paragraph 3 of Agreement Attached

 

. No Attachments at all.

 

The Next document is an Assignment and Bill of Sale from Bureau’s Investment Group Portfolio No 15 LLC to Midland Funding that is dated on May 7 2013.

 

This document has a lot of redaction then talks about Purchased accounts File, The Chain of Title File,  and Seller’s Accounts information

 

Then on the last page it Says This Bill of Sale is Executed without recourse or warranties except as stated and provided for in the agreement.

 

Again "No Agreement"

 

A field data sheet with my name and info

 

It says Data Printed by Midland Funding from electronic records provided by Bureau's Investment Group Portfolio No.15  LLC pursuant to the Bill of Sale/Assignment of Accounts transferred on or about 5/8/2013 in connection with the sale of accounts  from Bureau's Investment Group Portfolio No. 15 LLC to Midland Funding.

 

Affidavit of Bulk Sale of Accounts all of this took place in Delaware by the way.

 

There is also Bureau’s Investment Group Certificate of Sole Member  a Michael Slotky

 

Some more junk then some statements they say they sent me which I have never seen.

 

They included in passing that they would send a verification of all the junk in a few days.

 

We have a Case Management Conference scheduled for August 5th.

 

I sent out a meet and confer cmrrr because I have issues with the fact that they have not shown me anything that says I owe them any money.

They do not have any paper with my name and/or the alleged account number on it except 1 Orchard Bank statement from 12/2011.

 

I don't think that piece of paper means squat . It does not show or prove that Midland owns that account.

 

They sent me a case management statement and it says that we completed Discovery however (they stated in the answers to me  that discovery was ongoing they were still reviewing)

 

I sent Midland Funding my case management statement yesterday and I am filing it with the court today.

 

 Then today I got this verification as to responses Leslie Armento an employee of Midland Funding LLC. She is the servicer of the account in question.

 

@GinnyCoonrod

 

HI,

 

can you please PM a copy of Affidavit of Bulk Sale of Accounts all of this took place in Delaware by the way.

 

Thanks.

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We don't know what you mean to pm you a copy, this is something they would (the plaintiff) be sending you. A bill of sale and an affidavit saying they sold those accounts. In California it needs to swear by the laws of california

Edit....oh I thought you debt wars was the op

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It is going to be very difficult for Midland to prove the assignment in this case.  Since affidavits are not permitted at trial unless allowed by a specific statute (such as CCP 98), it will be very difficult for them to prove the transfer from HSBC to Bureau’s Investment Group III.

 

Plus, it appears there may be a missing transfer.  You noted that  Bureau’s Investment Group III received the transfer from HSBC.  But "Bureau’s Investment Group Portfolio No 15 LLC" assigned to Midland.  Where is the assignment from  Bureau’s Investment Group III to Bureau’s Investment Group Portfolio No 15 LLC?

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We don't know what you mean to pm you a copy, this is something they would (the plaintiff) be sending you. A bill of sale and an affidavit saying they sold those accounts. In California it needs to swear by the laws of california

Edit....oh I thought you debt wars was the op

 

No I am not OP....Just looking for research, direction and advice on this website.    Can you post a copy of Affidavit of Bulk Sale of Accounts here ?

 

Thanks.

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No I am not OP....Just looking for research, direction and advice on this website.    Can you post a copy of Affidavit of Bulk Sale of Accounts here ?

 

Thanks.

 

Then you should start your own thread and not hijack someone else's for your own purposes.

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Then you should start your own thread and not hijack someone else's for your own purposes.

 

@Clydesmom...If I am not mistaken GinnyCoonRod started this thread.  And I am NOT hijacking it.  I am here for the same reason as others...to learn, SHARE, seek advice, research and direction.

 

As well, if I am not mistaken, this is a California case, so it may not totally relevant for a Michigander.

 

Best Regards.

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It is going to be very difficult for Midland to prove the assignment in this case.  Since affidavits are not permitted at trial unless allowed by a specific statute (such as CCP 98), it will be very difficult for them to prove the transfer from HSBC to Bureau’s Investment Group III.

 

Plus, it appears there may be a missing transfer.  You noted that  Bureau’s Investment Group III received the transfer from HSBC.  But "Bureau’s Investment Group Portfolio No 15 LLC" assigned to Midland.  Where is the assignment from  Bureau’s Investment Group III to Bureau’s Investment Group Portfolio No 15 LLC?

 

would it be possible for Midland to assert an "identity of interests" for Bureau’s Investment Group III  and Bureau’s Investment Group Portfolio No 15 LLC ?

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@Clydesmom...If I am not mistaken GinnyCoonRod started this thread.  And I am NOT hijacking it.  I am here for the same reason as others...to learn, SHARE, seek advice, research and direction.

 

As well, if I am not mistaken, this is a California case, so it may not totally relevant for a Michigander.

 

Best Regards.

 

@

 

While  you both may be from the same state, and your cases may be SIMILAR NO two case are exactly identical and when you insert YOUR issues into their thread you confuse those people who believe they are answering the original person and not someone new with a different case.  You take away the attention from the OP and add your specific fact pattern.  Your questions may not be relevant to their case.

 

No one is discouraging you from learning but when you ask for information specific to YOUR case in someone else's thread you are hijacking it. The site rules ask that you not do this and that you start your OWN thread for the purpose of getting advice for your situation.  

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would it be possible for Midland to assert an "identity of interests" for Bureau’s Investment Group III  and Bureau’s Investment Group Portfolio No 15 LLC ?

 

 

Anything is possible.  However, you must ask yourself, how will Midland obtain admissible evidence that the two entities are the same (if, in fact they are, which I doubt)?  They would most likely either ignore the issue altogether or just print out something from a website.

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@

 

While  you both may be from the same state, and your cases may be SIMILAR NO two case are exactly identical and when you insert YOUR issues into their thread you confuse those people who believe they are answering the original person and not someone new with a different case.  You take away the attention from the OP and add your specific fact pattern.  Your questions may not be relevant to their case.

 

No one is discouraging you from learning but when you ask for information specific to YOUR case in someone else's thread you are hijacking it. The site rules ask that you not do this and that you start your OWN thread for the purpose of getting advice for your situation.  

 

Somehow I think you are very confused.  I simply asked for a copy of a document.  It is a simple yes or no request.

 

I am not inserting any issues to the thread.  Your comments are a complete distortion of my request.  So, we should both get off 

 

the owner's thread with these non-germane comments, and let others focus on the case at hand.

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I just went to court yesterday for my daughter who was sued by Midland Funding on Account Stated. Their lawyer met us in the hall before trial and tried to settle before trial.

I told her no and she handed my daughter a stack of papers supposedly proving the debt. I told her that everything she offered into evidence would be hearsay because we would object to the signed affidavit submitted with the Complaint.

I asked her if she had a witness and she said not, so I reiterated to hear that anything she admitted into evidence would be hearsay.

We went back into the courtroom and proceeded with trial. The first thing she did was tell the judge Midland Funding was dismissing the case without prejudice. That was it!

 

It sounds like you will have to go to trial, but winning against Account Stated is really pretty simple. I would be glad to show you what paperwork I filed and the arguments I made if you like. I would be willing to send you actual documents if it will help. I hate Junk Debt Collectors and would be glad to help.

 

BTW, I also got a dismissal from a Capitol One lawsuit filed against me. It went on for a year but finally won. 

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Thanks for sharing that @genebacon, and congrats to your daughter! It sounds like she was well prepared, but still, it takes some guts to stare down these JDBs all the way to the end of their bluff.

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I would really appreciate any help I can get. Yes I would like to see the arguments you used and the paperwork you filed and yes send me doc's if you don't mind! I went to the Case Management Conference and of course Midland had a Rent-a-lawyer there and believe it or not the Judge did not bother to show up. His bailiff scheduled all of the trials. They scheduled me for February 4 or 5 I think.

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I would also like to see your arguments and motions, as well as how your strategy played out.

 

Everytime one of these JDBs go down in flames, it helps!  Good job !

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Yes I would like to see the arguments you used and the paperwork you filed and yes send me doc's if you don't mind!

i would love to see those as well, if it not too much trouble.

I would also like to see your arguments and motions, as well as how your strategy played out.

 

my $0.02:

I'm sure the materials will be helpful, but remember that you're in California; the strategies used most often here to successfully defend vs JDB are based on a thorough understanding of the codes governing limited jurisdiction cases in this state.  Be sure to read (and re-read) key Ca. threads and codes.

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