azcappy

Retired And Being Sued By UNIFUND

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Hi!

 

Please advise what my next step is. I am in Arizona. On June 29th, I was served in person a Complaint from UNIFUND CCR, LLC. After reading the information provided here, I filed a Request For Production Of Documents on July 14th. To date, none have arrived (no surprise!).

 

Today I recieved an Application And Affidavit For Default And Notice Of Default. This document says that I "failed to plead or otherwise defend" (which is not true since I did respond) and that I have 10 days to file an answer.

 

I need to know what to file next. I don't understand why I received this Notice of Default. I need your help and advice.

 

Thank you!

 

 

 

 

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A request for documents and discovery is not an answer to the suit.  Did you file a separate answer to the lawsuit?  Even if you did answer again, since apparently the Plaintiff is not acknowledging it.  If you don't do something they will seek a default judgment and could win.

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Answer these questions @azcappy

If you are inquiring about a lawsuit in which you are the defendant (ie you are being sued), you need to answer the following questions (as much as possible):

1. Who is the named plaintiff in the suit?

2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.)

3. How much are you being sued for?

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

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

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

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

Process Service Requirements by State - Summons Complaint

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

9. What state and county do you live in?

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

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

Statute of Limitations on Debts

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).

13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?)

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.

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?

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.

17. what date was the suit filed?

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Thank you both for your help!

 

Here is the information I have:

1. Who is the named plaintiff in the suit?
    UNIFUND CCR, LLC
2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.)
    Hameroff Law Group, PC
3. How much are you being sued for?
    29,000
4. Who is the original creditor? (if not the Plaintiff)
    Citibank, NA
5. How do you know you are being sued? (You were served, right?)
    Served at home
6. How were you served? (Mail, In person, Notice on door)
    In person
7. Was the service legal as required by your state?
     yes
Process Service Requirements by State - Summons Complaint

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?
    Maricopa County, Arizona
10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations)
     Unknown - not on my credit report.
11. What is the SOL on the debt? To find out:
      6 years
Statute of Limitations on Debts

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).
  Online it shows complaint filed on 6/18 - my request for documents on 7/14 - latest is their application and affadavit of default   on 7/22
13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?)

      No - not on my credit report

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? (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 never received any communication from them before being sued. The complaint alleges a credit card debt from Citibank in the amount of approx. 29,000. I want to know what they are talking about so I filed the request for production of documents. They never sent any. There is no credit card number in the complaint. I did not receive an interrogatory. I have 10 days from their filing of this application and notice of default to respond. It was filed on 7/22.

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.

   None

17. what date was the suit filed?

    6/18 for complaint   7/22 for application and notice of default

 

It is clear to me that I need to file something else but I don't know what that is.

 

Thank you so much for any help!

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You need to file an answer with the court.  The request for production of documents is discovery it does not answer the suit.  Most likely the rules of civil procedure in superior court where you are being sued state that there is a very specific way to do discovery and you must answer the suit first.  That is probably why they haven't responded yet.

 

This is a LOT of money you should consult a consumer attorney ASAP.  Most will do it for free on an initial consultation.

 

First and foremost file an answer with the court ASAP.

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This is a large debt but the potentially good thing for you is that you are in Superior Court.

 

Is this a credit card debt?

When is the last time you think you paid on this account? Is it possible it's been more than 6 years?

When was the account opened?

 

Is it possible this is not your debt?  It's strange that it's not showing on your credit reports. Did you look at all 3 of them?

 

Can you scan the complaint (redact your personal info) and post it here?  And also the application for default?

 

 

As others have said, you need to file an answer to their complaint.  This is a line-by-line answer (admit or deny) to the things they state in their complaint.  You send one copy of your answer to Unifund's lawyers (Hammerhoff) and another copy to the court. You're on a time crunch with this now because they have applied for default.  You can type it up and post it here for critique.

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@azcappy

 

You mentioned that you're retired.  Is social security your only source of income?

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@azcappy

 

A couple of things.  If there is an off chance that this is your debt, when do you think that your last payment was made?  Have you received any correspondence/calls from Uni or an attorney regarding this alleged debt?

 

In your answer, you need to add your affirmative defenses, and any counterclaims you have against them.  Here is a thread on affirmative defenses:  http://www.creditinfocenter.com/community/topic/310699-lets-have-a-discussion-on-affirmative-defenses/?p=1131168

 

If you wish to pursue Contractual Arbitration, then you must also place that in your affirmative defense.

 

Also:

 

-  What is your tolerance for aggravation, time spent, and risk that you may lose in Court or Arbitration?  (i.e. Are you willing to fight, and spend the time it's going to take to potentially pull off a win, or a favorable settlement?)

-  Is it possible to settle the debt?  

 

These types of cases are about leverage, and an effective strategy.  The more leverage and better strategy will likely have a more positive outcome.  You do have some options, depending on your tolerance, time, and perseverance.

 

Here is a potential option, which I would likely pursue if this were me.

 

-  File my answer, along with all the affirmative defenses with the Court ASAP.

-  At the same time, file a Motion to Compel contractual arbitration (per the citi agreement, they have JAMS)

-  Once the motion to compel contractual arbitration is granted, I would then file a separate lawsuit for FDCPA and if applicable, the AZ UDAP (unfair, deceptive acts & practices).  Currently, they are seeking post charge-off interest, which is a violation of the FDCPA.  (can you tell us how much interest is being sought in Paragraph 6 of the Complaint?)

 

What the strategy above does, is provide monetary leverage against the JDB.  Arbitration will cost the JDB upwards of $10,000+++, not including attorneys fees, which will most likely be the same.  If by chance they win the Arbitration case against you, then you can appeal to a 3-Panel arbtration, which will cost the JDB another $30-60K (plus attys fees).  If you lose the 3-Panel appeal, then you can do a final Arb award appeal in Federal Court, which costs more attorneys fees.  If by chance the JDB follows you through all steps in this process, and wins the final award, you then have the final bit of leverage:  Bankruptcy, and they get nothing.

 

At the same time, you have an FDCPA case against them in Federal Court, which will cost them around $5,000 in attorneys fees, just to respond to the case.  Most likely the JDB purchased your account for approximately $1,500.  As you can see, it is not a prudent business decision to follow you into Arbitration, especially when you have a concurrent Federal FDCPA case against them.  This gives you a significant amount of leverage, and hopefully will cause the JDB to do a mutual walkaway, if the Arb & FDCPA cases are dismissed.

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@Coffee_before_tea

 

Currently, they are seeking post charge-off interest, which is a violation of the FDCPA.  (can you tell us how much interest is being sought in Paragraph 6 of the Complaint?)

 

 

The space in #6 for the rate of interest appears to be left blank.  In paragraph 7, they are seeking statutory interest from the date of filing which is allowed by law.  Of course, they'd have to provide a copy of the cardmember agreement to show that it allows for 29.9%.

44-1201. Rate of interest for loan or indebtedness; interest on judgments

 

A. Interest on any loan, indebtedness or other obligation shall be at the rate of ten per cent per annum, unless a different rate is contracted for in writing, in which event any rate of interest may be agreed to. Interest on any judgment that is based on a written agreement evidencing a loan, indebtedness or obligation that bears a rate of interest not in excess of the maximum permitted by law shall be at the rate of interest provided in the agreement and shall be specified in the judgment.

 

Berkeley Row, LLC v. Ruiz Court of Appeals, 2nd Div., Dept. A 2012

 

Here the judgment was based on debt incurred pursuant to a written credit card agreement that evidenced an "obligation." § 44-1201(A); see Black's Law Dictionary 1104 (8th ed. 2004) (An "obligation" includes "[a] formal, binding agreement or acknowledgment of a liability to pay a certain amount or to do a certain thing for a particular person or set of persons; esp., a duty arising by contract."); see also State ex. rel Ariz. Structural Pest Control Comm'n v. Taylor, 223 Ariz. 486, ¶ 11, 224 P.3d 983, 985-86 (App. 2010) (noting "obligation" includes binding agreements enforceable by law). That agreement "bears a rate of interest" after default of up to 29.99 percent. § 44-1201(A). Consequently, interest on the judgment "shall be at the rate of interest provided in the agreement"; the eighteen percent interest rate Berkeley sought was consistent with the agreement's terms, and the court erred in awarding a lesser amount.

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@BV80

 

It does appear to be blank, but did the OP redact it, or was it left blank by the JDB?  Question needs answered.  If there is an amount of interest that is added to the 29K (i.e. total of 25K + 4K interest = 29K), then that is what I'm referring to, when I say post charge-off interest.  Not the pre-judgment interest from 6/12

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@azcappy

In regard to initiating arbitration, I want to clear up some misinformation that was posted by Coffee.

 

The Arizona statute that deals with compelling arbitration (A.R.S. 12-1502) says that a motion to compel arbitration is proper when an agreement to arbitrate is shown AND there is a refusal to arbitrate by one of the parties.

 

Some here in Arizona have had success in filing a motion to compel with their answer, however there is a chance the court will deny the motion for not having all of the required elements.  At that point you have to then obtain a refusal from Unifund before again filing another motion to compel and you lose valuable time. 

 

Assuming this discussing tries to go the way all of the others on this same topic have, I'm going to tell you that you aren't waiving your right to arbitrate by not filing a motion to compel with your answer.  This has been shown to be the case time and again.  If you're interested,  you can search my name and 'arbitration' from the last 6 months or so and you can see that I and others have posted much case law on this subject and that what I'm telling you is in fact correct.

 

I'd also like to say that I believe Unifund will follow you into arbitration on this and I DON'T believe you will be able to wrack up anywhere close to $60,000 in arbitration/legal fees.  I believe you might get up around $10,000.  If I we're Unifund, it would be worth my while to pursue a $30,000 debt in arbitration under those circumstances. 

 

Be aware that I'm not going to argue with anyone about what I've said here.  It's been hashed out plenty and I'm confidant in my position and not interested in cluttering up yet another thread.

 

I will, however, be glad to answer any questions you have and, in whatever direction you go, help you the best I can. 

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I'm not even sure how this is relevant, as the OP said he'd get back to us after it is dismissed.  It appears they've embarked on a particular course, that doesn't necessarily include Arb...OP??

 

There is no misinformation in my post.  There are broad strokes in estimating potential arb costs & atty fees, however, those are the general cost ranges, especially if it goes to a 3-panel appeal.  I was merely pointing out the financial leverage which Arbitration provides.  OP, take a peek at debtorboards, and you'll find many people that have actual experience with Arb/JAMS that can elucidate the costs to a JDB in Arb.  Every case is different, and your results may vary.

 

In regards to your contention that a formal refusal must come from the JDB, I dispute that notion, and have (as before) provided case law that shows that by filing a lawsuit, and participating in litigation acts as a refusal to an Arbitration remedy.  Waiver = refusal (if they waive their right to arbitrate, then how can they later "agree" to arbitrate?)

 

Bolo Corporation v. Homes & Son Construction Co., 464 P. 2d 788 - Ariz: Supreme Court 1970
 
However, if either party, by his conduct can be said to have waived his right to arbitrate, the other party is placed in a position of choice: Either to compel arbitration under the contract, or to acquiesce in the waiver thereby making the revocation complete and binding on both.
 
The issue thus becomes whether an election to litigate is a waiver of arbitration within the above rule, and if so, was it too late under the facts of this case for the appellee to amend its complaint and attempt to compel arbitration under the agreement.
 
Quoting: Anderson v. Twin City Rapid Transit, 250 Minn. 167, 84 N.W.2d 593 (1957)
 
"The plaintiffs, whether bound by the clause or not, repudiated it by commencing this lawsuit and the defendants joined in the repudiation by answering to the merits without a demand for arbitration or a motion to stay the suit until arbitration could be had. Almost uniformly such conduct on the part of the parties constitutes an abandonment or waiver of the right to arbitrate and a consent to the submission of the controversy to the courts."

"Commencement of suit in a court rather than reliance upon arbitration, with answer by the opposing party upon the merits, is a waiver of the right to arbitrate by both parties. Galion Iron Works & Mfg. Co. v. J.D. Adams Mfg. Co., 7 Cir., 128 F.2d 411." 84 N.W.2d at 602.

"Waiver in this connection does not depend on timing of the motion to compel arbitration (where not unreasonably delayed), but rather on the prior taking of an inconsistent position by the party moving therefor. Thus, where a plaintiff, in disregard of his right to arbitrate, files suit for determination of the controversy, he will be held to have waived his right to compel arbitration thereof. The same will apply to a defendant who by counterclaim submits the matter, which was to be arbitrated, to the court for determination." 221 So.2d at 782.
 
Rancho Pescado v. Northwestern Mut. Life Ins., 680 P. 2d 1235 - Ariz: Court of Appeals, 1st Div
This court has stated that the "basis of the finding of waiver of an arbitration provision is the showing of conduct inconsistent with utilization of the arbitration remedy — conduct showing an intent not to arbitrate.

 

 

A California appeals case Hyundai AMCO America, Inc. v. S3H, INC., 232 Cal. App. 4th 572 - Cal: Court of Appeal, 4th Appel states:  "Arbitration can be refused without a formal demand ever having been made. Hyundai Amco's filing of a lawsuit rather than commencing arbitration proceedings as required by the agreement affirmatively establishes Hyundai Amco's refusal to arbitrate the controversy."

 

Also, the FAA preempts State law.

 

PaineWebber Inc. v. Faragalli, 61 F. 3d 1063 - Court of Appeals, 3rd Circuit 1995 "Our review of the record discloses that the only events which could have constituted a rejection of arbitration occurred either on May 2, 1994, when Faragalli filed his complaint in state court, or on June 10, 1994, when Faragalli for the first time expressly denied that his claims were subject to arbitration."

 

An article from the American Bar Assc. states:   "Whether the Plaintiff Has Refused to Arbitrate its Claims. The Act requires a court to compel arbitration upon finding a “failure, neglect or refusal” to comply with an arbitration agreement. This factor is satisfied when a party unequivocally refuses to arbitrate a dispute, by either (1) failing to comply with an arbitration demand, or (2) otherwise manifesting an intention not to arbitrate (such as filing a lawsuit in court)."

 

OP, if you wish to send a Arb demand letter to the JDB, then go right ahead, as it won't hurt you in any way.  However, there is no reason for you to wait for a response, or a formal refusal from the JDB, because you most likely will never receive one.  Not to mention, they have already shown conduct inconsistent with Arbitration, by filing a lawsuit against you.  This is a refusal to Arbitrate.

 

 

 

 

 

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@azcappy

 

There are some important items you must comply with, otherwise you may waive your right to Arbitration (if that's the route you want to take).  Some of those things are laid out in the case law I cited above.  Those are both from AZ.  Harry thinks he knows everything there is to know in AZ, just by simply living there and losing his cases in Justice Court.  You are in Superior court, and should have a real judge presiding.  

 

That being said, you have to be judicious in your strategy, as making the wrong step may waive your right to Arbitrate.  Things like:

 

-  Waiting too long to elect & compel Arbitration.  You have to demand it, and follow up with it.

-  Providing an answer to your complaint, without the Contractual Arbitration as an affirmative defense.

-  Asking for, or providing discovery, or disclosures

-  Filing a counterclaim with your answer.

-  Doing anything that could give the subject matter jurisdiction to the Court, and not Arb.  You want to do everything you can to remove yourself from their jurisdiction

 

Good luck OP!

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Coffee is spot on. I've recently done a little research, and by filing the suit, case appeals after case appeals, they waived their right for arb. You can use that as a refusal. I'm actually doing jury duty today,lol, interestingly enough google scholar is blocked here. Or I would look for as specific law.

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There is only one problem with compelling arbitration in this particular case:  the amount sued for.  A demand for Arb works to scare off a JDB when it is a debt of a few thousand making it not cost effective to pursue.  For $29k you can bet that they are more likely to follow this into arbitration or successfully argue in Superior Court to deny it.  

 

The major issue is this isn't Justice Court where it is the wild wild west and anything goes with some Justice of the Peace who likely has no legal training.  This is Superior Court that will follow ALL the rules.  Add to that the Hameroff firm is a bottom feeder who will use every sleazy tactic to steam roll the OP.  

 

While I would never roll over for Hameroff, the OP would be well advised to consult a consumer attorney at www.naca.net ASAP for that amount of money.  While they can't garnish SSI benefits a lien on a home could be a huge problem.

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I'm going to tell you that you aren't waiving your right to arbitrate by not filing a motion to compel with your answer.  This has been shown to be the case time and again.  If you're interested,  you can search my name and 'arbitration' from the last 6 months or so and you can see that I and others have posted much case law on this subject and that what I'm telling you is in fact correct.

 

Would you please say the case law that shows that filing answer before filing motion to compel doesn't risk waiving arbitration? I searched your name but didn't find case law to this specific question. Like if you filed answer then two weeks later filed motion to compel and the attorney then files opposition saying you waived by doing answer first, what case law would you argue back?

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Would you please say the case law that shows that filing answer before filing motion to compel doesn't risk waiving arbitration? I searched your name but didn't find case law to this specific question. Like if you filed answer then two weeks later filed motion to compel and the attorney then files opposition saying you waived by doing answer first, what case law would you argue back?

@kittycat

 

It depends on the state you are in, but the scenario you laid out typically wouldn't waive your right to Arb, as long as you included in your answer, an affirmative defense stating the issue is bound by contractual arbitration, and the court has no jurisdiction over the claim.

 

Are you in AZ or Maryland?

 

---Edit---

 

Adding to what I stated above, it's not a good idea to wait for any period of time (unless required by statute), to invoke your right to Arbitration (if that's the path you're taking).  In the course of the two weeks you waited to compel arbitration, the plaintiff could have sent their discovery requests, filed for Summary judgment.  This just makes things more complex, and the more complex things get, the odds increase on you waiving your right to Arb, or losing a summary judgment.

 

It's possible to appeal at that point, but why place yourself in that situation, when you don't have to.

 

If you wish to Arbitrate, move swiftly & deliberately to remove yourself, from the jurisdiction of the courts, and compel them into arbitration as soon as possible.

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@kittycat

Would you please say the case law that shows that filing answer before filing motion to compel doesn't risk waiving arbitration? I searched your name but didn't find case law to this specific question. Like if you filed answer then two weeks later filed motion to compel and the attorney then files opposition saying you waived by doing answer first, what case law would you argue back?

I'm glad you asked!

 

In this case the respondent answered the petition, filed a disclosure statement and was deposed, and the court still didn't find waiver had occurred.

 

Prejudice and, hence, waiver can be shown by significant participation in litigation. E.g., Northland Ins. Co. v. Kellogg, 897 P.2d 1161 (Okla. App. 1995) (plaintiff waived arbitration by filing petition, moving for summary judgment, and making discovery requests, putting defendant to considerable effort); Shimote v. Vincent, 905 P.2d 71 (Haw.Ct.App. 1995) (defendant waived arbitration by litigating for six years). Here, the only activity that has occurred since Staley answered the petition is that he filed a disclosure statement and was deposed. We find that such limited discovery, even though generally unavailable in arbitration, fails to show sufficient prejudice to warrant finding waiver.

Matter of Noel R. Shahan Trust, 932 P. 2d 1345 - Ariz: Court of Appeals, 2nd Div., Dept. B 1996

 

 

And this case analyzes 3 other case's rulings on waiver.

 

Public policy favors arbitration, see A.R.S. section 12-1501; thus, waiver of an appraisal clause, like waiver of an arbitration agreement, is generally not favored, and the facts of each case must be considered in light of the strong policy approving of arbitration. U.S. Insulation, 146 Ariz. at 258, 705 P.2d at 498; Rancho Pescado, 140 Ariz. at 181, 680 P.2d at 1242.

An arbitration provision is waived by conduct inconsistent with the use of the arbitration remedy; in other words, conduct that shows an intent not to arbitrate. EFC Dev. Corp. v. F.F. Baugh Plumbing & Heating, Inc., 24 Ariz. App. 566, 569, 540 P.2d 185, 188 (1975). Such conduct includes "preventing arbitration, making arbitration impossible, proceeding at all times in disregard of the arbitration clause, expressly agreeing to waive arbitration, or unreasonable delay." Id.

Meineke v. Twin City Fire Ins. Co., 892 P. 2d 1365 - Ariz: Court of Appeals, 1st Div., Dept. A 1994

 

 

As discussed in the previous case, filing an answer was not found to be conduct that shows in intent not to arbitrate.

 

 

So as you can see, there is absolutely no validity to any claim that an Arizona defendant is in danger of waiving arbitration merely by filing an answer.

 

 

P.S. These are Arizona cases, which is the subject of this topic.  If you're asking about how it works in Maryland, you're best bet is to start your own thread and ask for information specific to Maryland.

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Thank you Harry Seaward.  I understand that it will be different in my state.  I still wanted to read some reasoning about if an answer waives anything.  Thanks for listing the cases for me to read.

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Hi!

 

After my last post, I receved a large envelope in the mail containing thes documents from the Plantiff:

First Request For Admissions

Request For Non-Uniform Interrogatories

Request for Production of Documents

Also their typical response to my request for production of documents - their employee's statement, computer printouts, and a copy of a letter that was allegedly sent to me (I did not receive it).

 

I attached the responses I have prepared and would appreciate any suggestions. On the non-uniform Interrogatories, I left the answer to Interrogatory 11 blank. Should I provide a different reply?

 

I am also attaching a compulsory arbitration notice that was included with the original complaint.

 

Thank you so much for you help!

 

 

Unifund - posted first req for adm.pdf

Unifund - posted req for non uni.pdf

Unifund - posted comp arb.pdf

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