vondutch0481 5 Posted December 5, 2014 Author Report Share Posted December 5, 2014 @helping greg is there a template for a number pleaded paper , so for my denial i was told not to be specifi in anything just lists some affirmative defenses Quote Link to post Share on other sites
vondutch0481 5 Posted December 5, 2014 Author Report Share Posted December 5, 2014 @mrdwop do you still hace the old documents from your case with CACHE? Quote Link to post Share on other sites
sadinca 772 Posted December 5, 2014 Report Share Posted December 5, 2014 I would post the template here but its on my work computer. Check on the samples in STMedic or homeless in california. I thinkbthere are some. Maybe a google seach would bring something up too. Quote Link to post Share on other sites
sadinca 772 Posted December 5, 2014 Report Share Posted December 5, 2014 here, you go. i found it in my laptop. just put your personal info, court branch, case number, document title, and foot note.may be ready to go as far as spacing is concern.Declaration of Defendant in Support of Defendant's Objection to Declaration in Lieu.doc Quote Link to post Share on other sites
HelpingGreg 30 Posted December 5, 2014 Report Share Posted December 5, 2014 Here is your hyperlink to select from several options regarding free access to numbered legal pleading paper online,http://www.google.com/#q=numbered+legal+pleading+paperI use the templates provided for free on Internet and have had no issues.Warmly, 1 Quote Link to post Share on other sites
HelpingGreg 30 Posted December 5, 2014 Report Share Posted December 5, 2014 Please, focus on doing a good job at school as your education really will serve you all the days of your life.Of course, remain proactive toward this case - already, by doing so you are in the top 5% of consumer litigants, most by far default judgement burdened due to their failure to answer, or otherwise follow forward through the process. Keep on keeping on!It was your closing sentence, above, about stress that compelled me to write this to you. You are not-at-all defined by this consumer account, or the plaintiff's complaint. When I think of you, the one word I see as your label is, "Student". And, when most anyone thinks, "Student", they think of someone working today for a better & brighter forevermore. THAT is others' perceptions of you. I hope you embrace that as your reality and in so doing feel pretty dang good about who you are, and who you are becoming!You probably were exposed to this in your freshman campus intro. course, but, just as a refresher - to get that stress lowered - take a timer, (many cellphones & microwaves have them built-in), and set it, alternatingly, for 45 & 15 minutes. Remember? For optimal results, study 45 minutes, (Yes, researching your case online / on-site IS a form of studying!), then, get up, walk around, stretch, exercise - get the blood oxygenating & flowing! - hydrate, nurish, and, potty break, washing face & hands, or, even a quick rinse off, brisk towel-off, and slip into fresh clothing, then, back to the research & preparations. And, importantly, maintain a healthy sleep schedule!This is not-at-all worth the damage stressing does to the human body. Many have come before you, won, and remain to mentor you via free peer-to-peer support. Expert NACA member Consumer Law attorneys give of their professional expertise here, freely. You are in excellent company. Please, take some deep cleansing breaths, adjust your perspective, and release the stress.Just think of it! One postgraduate day, the sum of this suit may likely be less than your weekly take-home pay! "-)Then, we can all go out for probiotic Yogurtland, your treat! LOL! Joking! <8^DWarmly, Quote Link to post Share on other sites
HelpingGreg 30 Posted December 5, 2014 Report Share Posted December 5, 2014 @helping greg is there a template for a number pleaded paper , so for my denial i was told not to be specifi in anything just lists some affirmative defensesOopsies! I almost deleted this notification without addressing the "Affirmative Defenses" portion.Two things + two things follow,Thing 1.) Some litigants have gone forward with a veritable Dagwood sandwich-high pile of Affirmative Defense entries, I saw one list 2 pages long! 1b.) There is no obligation to include Affirmative Defense (s) on your PLD 050; General Denial is sufficient.1c.) If you discover, for example, your last activity on the account was, say 2003, but it was misread as 2013, totally go for the Statute of Limitations, (SOL) Affirmative Defense, and include SOL proof, if you just want this to go away on the PDQ, is what I would do.1d.) Lack of Standing, (LOS), is the other Affirmative Defense frequently added to the PLD050. I think that one is abundantly self-explanatory.Thing 2.) Some litigants have gone forward with not one iota of an Affirmative Defense and they've done just fine, as in they've won their case without including Affirmative Defenses.2nd Thing 1.) You can always request to amend your PLD050 later, including your Affirmative Defense (s) at that time.2nd Thing 2.) You can always let any Affirmative Defense(s) become discarded, "I will no longer persue that.", just sliding it off your back as though you are made of Teflon.I hold the words of @calawyer in high esteem, and note the frequency of no need to include Affirmative Defenses in my Calawyer readings.Perhaps Calawyer will post here. If so, those would be the words determining my ultimate course of action.Lastly, please do remember to prepare 3 copies, but only provide 2 sets to the Civil window at the Office of Clerk of the Court for stamping.1.) The Original PLD050 & POS,for the deputy clerk to stamp & file;2.) The identical photocopy set of all in #1,for the deputy clerk to stamp "FILED", instantly returned to you as your conformed copy3.) The other of the (2) identical photocopy sets of all in #1,for the plaintiff to receive NOT STAMPED "FILED",3a.) via USPS Certified Mail, Registered, Return Receipt Requested (the green postcard)3b.) via UPS PRIORITY MAIL, includes tracking, around $11.00, extended hours & weekends3c.) via USPS PRIORITY MAIL, includes tracking, under $6.00, business hoursPick from 3a. - 3c., or share other options, please. And, mail the answer same day as filed in the courthouse, to the Plaintiff's address on the Summons / Complaint.Thanks to the ALWAYS EXCELLENT words of @Homelessinca I have saved enough for a tank of gasoline already, easily, by using option 3c.Best of success to you!Warmly, Quote Link to post Share on other sites
mrdwop 17 Posted December 6, 2014 Report Share Posted December 6, 2014 @mrdwop do you still hace the old documents from your case with CACHE?yes. I will dig them out and try to post what i got. I just have to edit some info. Ill try to work on it tonight since i got free time. Where are you at on the case right now, did you already answer Quote Link to post Share on other sites
mrdwop 17 Posted December 7, 2014 Report Share Posted December 7, 2014 these are scanned answers to my complaint. Quote Link to post Share on other sites
HelpingGreg 30 Posted December 7, 2014 Report Share Posted December 7, 2014 @mrdwopPlease, oh please,walk me through how toupload *.JPEG scanned files to the site!Thanks in advance!Warmly, Quote Link to post Share on other sites
mrdwop 17 Posted December 7, 2014 Report Share Posted December 7, 2014 @mrdwopPlease, oh please, wal me through how to upload *.JPEG scanned files to the site!Thanks in advance!Warmly,@HelpingGreg No problem.On the bottom right, under the 'Reply to this topic' box click 'More Reply Options' then on the bottom says 'Attach Files' the click 'choose file' and pick the file from your computer you want to upload. then post. Hope that helps what your looking for. Quote Link to post Share on other sites
HelpingGreg 30 Posted December 7, 2014 Report Share Posted December 7, 2014 OK!I am trying to upload using Samsung Galaxy 3 10.1It is Android.I click Attach and no files display.I click Basic Uploader and immediately get to delve among both downloaded doc & images and everything else sent to, or created with, this machine, (Android).Do I need some app, or, ???Sorry to be doing this right here, right now - my court is 10a.m., tomorrow and I have wanted to / been trying to upload some pages for critique with increasing intensity since October, and very most strongly since our hearing two weeks ago, tomorrow, (when they ganded over their thick stack of pages, saying, and I quote, "Don't bother with any but the last page, it's the only one the matters.", in tones as though he were my loving & caring grandpa, the family attorney, just looking out for his favorite grandchild - me, not CACH! LOL!I keep thinking that was a violation, not to mention hounding me at my heels, totally scant micrometers from me, all the way, only stopping to admire my car, which is when we finally parted company...isn't that an offense as well?Anyway!Not-at-all expecting answers on this, your-not-mine thread, just laying the basis for the usual upload instructions not working for me + my reason for desperately wanting to upload, (before court tomorrow), plus, my usual tanget, (about the opposition's perceived violations), but that's just me! LOL!Remember that Ray Stevens song, back in the weird mid-70s "daze"/days, "They Call Him the Streaker", well, change "streaker" to "rambler" and that's me! Looie here! Lookie there! Ramblin' rambler's everywhere! (((sigh))) I am pretty sure I have the 20-hours-to-court mental melt-aways and just need to exercise some selfcare, and.stop.rambling! LOL!It goes without saying, please send positive energies for tomorrow's 10a.m. court.Will update elsewhere afterward.Warmly,P.S., This is the song. Just click to play for free on YouTube., down 3 or 4 comments on the YouTube page is an interesting synopsis of Streaking, too.Hard to believe this decade's stodgie old retirees were the ones running around as naked as a buck white-tailed deer in Spring!I suppose the synopsis of the rambler won't ever be gotten around to - too busy ramblin' to get on-point! LOL!CLICK! Quote Link to post Share on other sites
vondutch0481 5 Posted December 9, 2014 Author Report Share Posted December 9, 2014 thank you no i havent responded to them yet , but i did download the forms to respond to Maybe i should list the affirmative defenses since i dont have a lawyer and i think its a lot to type in a numbered paper thank you thoughthese are scanned answers to my complaint.PTDC0027.JPGPTDC0028.JPGPTDC0029.JPGPTDC0030.JPGPTDC0031.JPGPTDC0033.JPGPTDC0034.JPG Quote Link to post Share on other sites
HelpingGreg 30 Posted December 9, 2014 Report Share Posted December 9, 2014 thank you no i havent responded to them yet , but i did download the forms to respond to Maybe i should list the affirmative defenses since i dont have a lawyer and i think its a lot to type in a numbered paper thank you though@calawyer@Homelessinca@Anon Amos@Seadragon@ASTMedic@Coltfan1972and others here have both professional NACA member expertise and bountiful successful experience for peer-to-peer (free!) support.Perhaps you will have both the interest & time to entertain a reading of their input in response to your thoughts of using a bevy of Affirmative Defenses to save yourself from typing too much?Wishing you a successful outcome against our common opponent, I encourage you to at least hear them out. They have been in our shoes and come out winners!Please, know that I gently & softly mention quietly to you, ... neither a bevy of Affirmative Defenses, nor any attempts toward saving keystrokes were involved in any of their victories...Wishing you a willingness to hear the proven winners out, and, your own win against CACH.Warmly, Quote Link to post Share on other sites
Anon Amos 2,247 Posted December 9, 2014 Report Share Posted December 9, 2014 Way too many affirmative defense and many of these are incorrect as well. If you don't have SOL as a defense then you probably just deny. 1 Quote Link to post Share on other sites
vondutch0481 5 Posted January 27, 2015 Author Report Share Posted January 27, 2015 @HelpingGreg I have recieved another document from CACH , LLC 's Attorney it is a DISC-004 form called FORM INTERROGATORIES ( ECONOMIC LITIGATION) i dont really know how to respond to these forms , i can upload photos of them . thanks ! Quote Link to post Share on other sites
sadinca 772 Posted January 28, 2015 Report Share Posted January 28, 2015 if you need help answering their ROGS post the questions here, I think that would be easier than posting the actual redacted doc. 1 Quote Link to post Share on other sites
shellieh98 1,505 Posted January 28, 2015 Report Share Posted January 28, 2015 Did you ever send a BOP as suggested? Quote Link to post Share on other sites
Seadragon 840 Posted January 29, 2015 Report Share Posted January 29, 2015 What number boxes are checked? We can go through each response. Quote Link to post Share on other sites
vondutch0481 5 Posted March 2, 2015 Author Report Share Posted March 2, 2015 What number boxes are checked? We can go through each response.@ helpingreg So i got the Form " FORM INTERROGATORIES ( ECONOMIC LITIGATION) Sorry late response !!Boxes that are checked are 102.1102.4102.5 115.2 " state in detail facts uponwhich you base your contention that you are not responsible in whole or in part for plantiff's damages[ how do i irespond to this ? ] i mean they want me to admit the debt .I know i owe debt before ..but i didnt think that i would get sued for a debt of 1k? Quote Link to post Share on other sites
credit2011 105 Posted March 2, 2015 Report Share Posted March 2, 2015 Not sure if you addressed this above, in your complaint do they use the word "contract", and "agreement" ? Do they say anything about "the agreement" and specifically the "agreement between you and them" in any of the paper work you got from them? If so this is what will be your defenses in court, they have to provide those items they are mentioning and using in your complaint are suing you for. This is part of the assignment of debt they have to prove. I have not read your case in full here, but will try soon. Just remember you did not sign any agreement with them and if so or not, they need to provide a signature of yours as such to prove their case. Quote Link to post Share on other sites
vondutch0481 5 Posted March 3, 2015 Author Report Share Posted March 3, 2015 Not sure if you addressed this above, in your complaint do they use the word "contract", and "agreement" ? Do they say anything about "the agreement" and specifically the "agreement between you and them" in any of the paper work you got from them? If so this is what will be your defenses in court, they have to provide those items they are mentioning and using in your complaint are suing you for. This is part of the assignment of debt they have to prove. I have not read your case in full here, but will try soon. Just remember you did not sign any agreement with them and if so or not, they need to provide a signature of yours as such to prove their case. @credit2011 Hi , No i didnt sign any agreement with CACHE, the letters they gave me doesnt MENTION any type of agreementdfrom my understanding what is stated in FIRST CAUSE OF ACTIOn which the pictures are posted on here in Page 1 of this topic.anyway on Column 8 it is stated " On or about september 13 ,2013 Original creditor assigned or otherwise transferred all of its right , title , and interest in the account and plantiff is the present holder of allright atitle and interest in the account.. Quote Link to post Share on other sites
Anon Amos 2,247 Posted March 3, 2015 Report Share Posted March 3, 2015 @HelpingGreg I have recieved another document from CACH , LLC 's Attorney FORM INTERROGATORIES ( ECONOMIC LITIGATION) i dont really know how to respond to these formsYou need to answer these, You have 30 days +5 days (if they mailed) to respond. It's 35 days from the day it's postmarked to get your to response in the mail. Quote Link to post Share on other sites
Anon Amos 2,247 Posted March 3, 2015 Report Share Posted March 3, 2015 115.2 " state in detail facts uponwhich you base your contention that you are not responsible in whole or in part for plantiff's damages[ how do i irespond to this ? ]Response: Plaintiff alleges in it's complaint that defendant became indebted to OC and failed to make payments therefor damaging OC. Plaintiff alleges an assignment to the debt and would not have been damaged. If plaintiff purchased the debt in attempts to profit then it would have caused it's own damage. I would answer it with something like that if it were mine. Quote Link to post Share on other sites
vondutch0481 5 Posted March 3, 2015 Author Report Share Posted March 3, 2015 @ helpinggreg @Seadragon SO on the DISC-004 form aka FORM INTERROGATORIES ( economic litigation) on 115.2 stated : State in detail the facts upon which you bse your contention that you are not responsible, in whole or in part . for plantiffs damages. How do i respond to that , i know that i have no contract or agreement with cach . They have sent me an attatched Documents to be producedTHEY WANT COPIES OF THE FOLLOWING1. Copies of any and all correspondence between me and agents . etc.2. Copies of any documentation evidencing any payments made to ORIGINAL CREDITOR AND CREDIT ACCOUNT3. COPIES of any and all documents that support the affirmative defenses raised by YOU In this actin4. COPIES OF ALL CORRESPONDENCE from you regarding false or factually incorrect claims or statement that you believe were made to various credit reporting bureaus or services about the credit account im lost , confused , ,,do i provide the following that is stated above to them? i mean they listed HSBC BANK NEVEDA N.A. & AFFILIATES and the account number....but they never stated if it is a Bestbuy creditcard , Quote Link to post Share on other sites
