LaneBlane

Attacking a JDB’s Standing | Need to Respond to Interrogatories, RPD, RA

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It's hard to find answers to questions when you live in Minnesota and not in a more heavily populated state.

It looks like I am one day beyond the period of time I had to give notice.  (Damn Columbus Day!)    I haven't been able to find out any information on what may happen as a result.  This is what I assume could happen:

  • If the plaintiff sends an attorney two-hours to appear in court, they could argue my MTC Arbitration should be denied based on my failure to provide sufficient notice of the hearing.
  • If nobody appears for the plaintiff, the judge could grant my MTC Arbitration.  The plaintiff could then appeal the decision based on improper notice.

If the other side doesn't send a representative to court, I could admit my mistake to the judge and ask the court to postpone my case to another date to allow me to offer proper notice.  If the plaintiff's attorney is there, I have to assume they won't want to make things easy for me.

Any input would be greatly appreciated at this point.

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  I can definitely say I don't wish this experience on anyone.

In case my MTC Arbitration is denied, I'm continuing to put together my defenses.

The plaintiff has made it very difficult for me to respond to their discovery and their complaint in general.  They have defined the term "Loan" as referring to all the loans between the OC and me.  There are ten different loan agreements of varying amounts, fees, and payment schedules.

For example, one of the plaintiff's interrogatories is "If you contend the Loan balance is not correct, state the reason for the contention."  How can I possibly respond when there are ten loan agreements and the plaintiff hasn't provided an itemization showing how much they claim is owed on each loan?

Can a plaintiff lump ten separate loan agreements together and claim one amount owed on everything collectively?

Here are my defenses so far:

1. The Plaintiff has failed to provide Defendant with an itemization of the balance they allege remains on each loan agreement.  Therefore, the Complaint is vague and ambiguous, and lacks sufficient specificity for the Defendant to frame an answer.

2. The Plaintiff provided the Defendant with copies of the ten written contracts. When compared to the loan history obtained from the original creditor, the contracts provided reflect incorrect loan dates.

3. Copies of the ten loan contracts provided to the Defendant by the Plaintiff do not contain any signature pages, and there are no indications of any electronic signatures, nor any markings, attachments, or associations verifying electronic signatures exist.  According to the Uniform Electronic Transactions Act (UETA) Section 2(8) an electronic signature is defined as "an electronic sound, symbol, or process attached to or logically associated with a record and executed or adopted by a person with the intent to sign the record." 

4. The Plaintiff claims they have standing to sue after taking title to the subject loans via a Bill of Sale and Assignment from XXXXX.  This Bill of Sale and Assignment indicates the Plaintiff  is purchasing “certain charged-off accounts” that are listed on a schedule of charged-off accounts attached to the agreement.  Because that schedule has not been provided, it is unclear whether the subject loans were included in the purchase.  As such, it is unclear whether Plaintiff has standing to bring this action.  (Rules of Evidence, Hearsay)

5. I've been through all ten contracts, have compared them against my payments, and determined I was overcharged to the tune of approximately $1,700 in fees.  These aren't late fees.  These are fees related to the cost of the loan.

 

 

 

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Wait, if the hearing date is this Monday, why did you not send out the motion and notice of hearing when you got which would have been way before the 16th. That would have been easier than this day counting and holding off until the last minute. The court knew you needed at least 5 court business days and would have given you that.

What the court will do if you failed to follow the rules is make you go back and refile the motion (paying another fee) and doing the service again. That is what they do when landlords mess up the Unlawful Detainer process. However, in order to claim a defense against a motion because the rules have not been followed, they will have to bring that to the attention of the judge, either written or orally. This is the same where a defendant has to bring up the fact that SOL has passed or they are denied that defense. If the plaintiff does not show up to oppose the motion or send something written to the judge, they cannot appeal the fact that you messed up the dates later. It is a situation of speak now or forever hold your peace.

As for the claim that the amount is messed up, in the discovery, I would answer for the accounting stating that the plaintiff has not given an accounting of the proper amount for each loan and thus you cannot match up to your records what the correct amounts would be. I would then in my discovery to the plaintiff demand an accounting for each loan from the point where the balance was 0. As for the signatures, they could be saying that this is an account stated case where signatures are not required to enter into a binding contract. If so, then the e-signatures are not needed. As for standing, there are other posts around here that deal with that.

Minnesota is hard because of the fact that cases are not started by filing in the court. In fact, you are in a unique position that they filed so fast because most of the time, that is not what happens. Usually, if a plaintiff realizes that they might lose a case, they just walk away so nothing is ever filed except for the default judgement cases.

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I have to ask, were these payday internet loans? If so, you might want to read this:

https://www.ag.state.mn.us/consumer/publications/InternetLoans.asp

The state courts have already backed up the attorney general and the state in the fact that the state can regulate these loans to state residents:

http://www.ballardspahr.com/alertspublications/legalalerts/2015-10-29-commerce-clause-does-not-prevent-minnesota-regulating-internet-loans-made-state-residents.aspx

This means that you need to check to see if the company indeed followed the rules. If not, that might be a defense that the company cannot enforce its illegal loans in Minnesota.

Just another angle.

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13 hours ago, WhoCares1000 said:

Wait, if the hearing date is this Monday, why did you not send out the motion and notice of hearing when you got which would have been way before the 16th. That would have been easier than this day counting and holding off until the last minute. The court knew you needed at least 5 court business days and would have given you that.

This has everything to do with the fact that the Court Clerk in my small, rural town was out for more than a week, at the time when I needed to get a few things done.  The Deputy Clerk who was left in charge was pretty new and wasn't familiar with procedure at all.  The office was also closed a few times when I got there because there was only one person in the clerk's office, and they were closed when that person had to leave to run errands or go to the Post Office.

 

13 hours ago, WhoCares1000 said:

What the court will do if you failed to follow the rules is make you go back and refile the motion (paying another fee) and doing the service again. That is what they do when landlords mess up the Unlawful Detainer process. However, in order to claim a defense against a motion because the rules have not been followed, they will have to bring that to the attention of the judge, either written or orally. This is the same where a defendant has to bring up the fact that SOL has passed or they are denied that defense. If the plaintiff does not show up to oppose the motion or send something written to the judge, they cannot appeal the fact that you messed up the dates later. It is a situation of speak now or forever hold your peace.

Thanks for providing me with this information.  If the other side doesn't oppose the motion in person or in writing, I take it that I should keep my mouth shut about the timeline and make my case for the MTC.

If the other side brings up the timeline in person or in writing, I will ask the judge to allow me to refile the motion.

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14 hours ago, WhoCares1000 said:
I have to ask, were these payday internet loans? If so, you might want to read this:

https://www.ag.state.mn.us/consumer/publications/InternetLoans.asp

The state courts have already backed up the attorney general and the state in the fact that the state can regulate these loans to state residents:

http://www.ballardspahr.com/alertspublications/legalalerts/2015-10-29-commerce-clause-does-not-prevent-minnesota-regulating-internet-loans-made-state-residents.aspx

This means that you need to check to see if the company indeed followed the rules. If not, that might be a defense that the company cannot enforce its illegal loans in Minnesota.

Just another angle.

These weren't payday internet loans.  Thank you for considering this angle for me.

 

14 hours ago, WhoCares1000 said:

As for the signatures, they could be saying that this is an account stated case where signatures are not required to enter into a binding contract.

I've always associated "account stated" with credit cards and running tabs.   When I looked at the definitions of "account stated" I can see a few similarities.  However, my business loans didn't involve a monthly bill, invoice, or running balance.  I made automatic payments that were specified in each loan agreement.

Looking at the original complaint, there is no mention of the term "account stated."  Here are the complaints:

  • Defendant entered into a series of loan agreements with xxxxxxxxxxxxxx.
  • Defendant breached the terms of the loan agreements by failing to make the minimum monthly payments on the loans.
  • That as a result of the breach, defendant owes the plaintiff $xxxxxxxxx plus interest from [date].

The electronic signature issue is something I thought I should consider bringing up as a defense.  This alone is weak, I admit.  When you add the fact that the dates on the loan agreements don't match the dates on my loan history printed from the OC's website, it seems like sufficient grounds for me to say I neither admit nor deny the loan agreements provided are true and correct copies.

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I've put together a "cheat sheet" to take to court with me.  It includes responses to oppositions the plaintiff may bring up.

Is there anything else I should be prepared for?  Also, are there any important guidelines or strategy I should follow in case the other side has a representative at the hearing who approaches me with an offer?  I don't know if it's a good idea for me to bring up the $1,700 in fee overcharges and show them how I calculated the discrepancy.

 

The Plaintiff sued on “account stated” and therefore no contract is required.

Plaintiff has provided me with copies of the loan agreements that contradict their opposition.  Further, the Plaintiff’s Complaint does not state they are suing on “account stated.”

You waived your right to arbitration by engaging in substantial litigation.

I filed an answer to the Plaintiff’s Complaint in order to prevent a default judgment.  The Plaintiff sent their first set of interrogatories, request for documentation, and request for admissions on [date].  I responded to these requests pro-se with objections due to the pending Motion to Compel Arbitration.

Case belongs in Small Claims and not in Arbitration.

The Plaintiff chose their path and must follow it.  They filed a civil complaint and should not be permitted to move the case to a different court because they are not happy with the outcome.

Arbitration is more expensive and court makes more sense.

Because the Plaintiff contends they are the owners of the loan agreements in question, they assume the role of the original creditor and cannot eliminate parts of the contract they don’t like.

The contract provided is not correct

The contracts I am referring to were furnished by the Plaintiff as Exhibits 1-10 to their Request for Admissions.

Plaintiff purchased the account from the original creditor and is not bound by the Arbitration Agreement

Section 1.6 of the loan agreements states that any claim, as defined below, will be resolved by binding arbitration.  The paragraph of the Arbitration Agreement Clause titled Broad Meaning of Claims (vi/6) defines “Claims” as including “Claims between you and us or our parent corporations, wholly or majority owned subsidiaries, affiliates, predecessors, successors, assigns, agents, independent contractors, employees, officers, directors or representatives arising from any transaction between us pursuant to this Agreement.” 

Because the Plaintiff contends they purchased the loan agreements from xxxxxx, they are bound to resolve claims in accordance with the arbitration agreement.

Defendant will be responsible for paying filing fees and other fees related to arbitration.

Section 1.6 of the loan agreements, paragraph titled Arbitration Procedure and Costs, reads, “No matter which party initiates the arbitration, we will advance or reimburse filing fees and other costs or fees of arbitration.”  This paragraph does not give the Plaintiff discretion over whether the fees and costs of arbitration are advanced or reimbursed.  Therefore, I argue the Plaintiff must advance the filing fees and other costs or fees of arbitration upon request.

Further, because the Plaintiff has not fulfilled their contractual obligation under the arbitration agreement, I have no confidence that they will reimburse any fees or costs under this paragraph.

GOVERNING LAW FOR ARBITRATION

Section 1.6, Paragraph titled Governing Law for Arbitration, states the Arbitration Provision is made pursuant to a transaction involving interstate commerce, and will be governed by the Federal Arbitration Act (“FAA”), 9 U.S.C. §§ 1 et seq., as amended, notwithstanding any other governing law provision in this Agreement.

The Federal Arbitration Act (FAA) 9 USC, Section 1-2 provides:

“A written provision in any maritime transaction or a contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction or the refusal to perform the whole or any part thereof or an agreement in writing to submit to arbitration an existing controversy arising out of such contract, transaction, or refusal, shall be valid, irrevocable and enforceable save upon such grounds as exist at law or in equity for the revocation of any contract”.

CASE LAW

The Supreme Court Ruling, decided April 27, 2011, AT&T MOBILITY LLC v.

CONCEPCION ET U, (BRING COPY) states that courts must enforce arbitration agreements according to their terms. If there is an arbitration clause in the contract, that clause must be honored.

“We have described this provision as reflecting both a “liberal federal policy favoring arbitration,” Moses H. Cone , supra, at 24, and the “fundamental principle that arbitration is a matter of contract,” Rent-A-Center, West, Inc. v. Jackson , 561 U. S. ____ , ____ (2010) (slip op., at 3). In line with these principles, courts must place arbitration agreements on an equal footing with other contracts, Buckeye Check Cashing, Inc. v. Cardegna , 546 U. S. 440, 443 (2006) , and enforce them according to their terms, Volt Information Sciences, Inc. v. Board of Trustees of Leland Stanford Junior Univ. , 489 U. S. 468, 478 (1989).”

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The issue is, even as pro se, you are expected to know the rules of civil procedure and follow them. The clerks are not allowed to give legal advice, even on those rules and you are expected to know how the clerks office is operating. This is especially true in Minnesota where the courts have been woefully underfunded by the state government for many years which has caused many issues, even in criminal cases. In any case, I would wait and see what happens. The worst case scenario is that the MTC is denied and you are going to trial. You might still have some defenses.

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Forget the garbage about costs for your MTC hearing. That is for JAMS to deal with and not court. If it is brought up, the only answer you need is that you are aware of the rules of the arbitration forum and what it entails and I still wish to exercise my contractual right to private arbitration.

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14 hours ago, WhoCares1000 said:

The issue is, even as pro se, you are expected to know the rules of civil procedure and follow them. The clerks are not allowed to give legal advice, even on those rules and you are expected to know how the clerks office is operating. This is especially true in Minnesota where the courts have been woefully underfunded by the state government for many years which has caused many issues, even in criminal cases. In any case, I would wait and see what happens. The worst case scenario is that the MTC is denied and you are going to trial. You might still have some defenses.

I'm walking into the hearing prepared.  If the lack of service is brought up, I'm hoping the court will allow me to refile and reschedule a hearing date.  If the MTC is denied, I'll cross that bridge when and if I get there.

Thank you for your input and guidance.

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11 hours ago, fisthardcheese said:

Forget the garbage about costs for your MTC hearing. That is for JAMS to deal with and not court. If it is brought up, the only answer you need is that you are aware of the rules of the arbitration forum and what it entails and I still wish to exercise my contractual right to private arbitration.

Thanks for the advise.  I made this change.

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The plaintiff sent a writing to the Judge stating they did not oppose my MTC Arbitration.  The Judge granted my motion and stayed the proceeding until arbitration has been concluded.

My next step is filing with JAMS and (hopefully) getting JAMS to collect the $1,200 filing fee from the plaintiff.  Below is the paragraph from my agreement on arbitration procedure and costs.  I've underlined two things.

The contract clearly states the other side will advance the filing fee.  (They are not given the discretion of deciding between advancing or reimbursing.) The line about my possibly having to pay fees, costs, expenses, etc., (if the other party substantially prevails)  is a little concerning.

Arbitration Procedure and Costs. For a copy of relevant codes of procedure, to file a Claim or for other information about JAMS and AAA, write them, visit their web site or call them at: (i) for JAMS, 1920 Main Street, Suite 300, Irvine, CA 92614, info@jamsadr.com, http://www.jamsadr.com, or 1-800-352-5267; or (ii) for AAA, 1633 Broadway, 10th Floor, New York, NY 10019, websitemail@adr.org, http://www.adr.org, or 1-800-778-7879. If either party fails to submit to arbitration following a proper demand to do so, that party will bear the costs and expenses, including reasonable attorneys’ fees, incurred by the party compelling arbitration. Any physical arbitration hearing will be held in the federal judicial district selected by Merchant. No matter which party initiates the arbitration, we will advance or reimburse filing fees and other costs or fees of arbitration. Each party will initially be responsible for its own attorneys’, experts’ and witness fees and related costs and expenses. Unless prohibited by law, the arbitrator may, applying applicable law, award fees, costs and reasonable attorneys’ fees and expenses to the party who substantially prevails in the arbitration. The allocation of fees and costs relating to an appeal in arbitration will be handled in the same manner. For an explanation and schedule of the fees that may apply to an arbitration proceeding, please contact the organizations at the addresses above. The appropriate fee schedule in effect from time to time is hereby incorporated by reference into this Arbitration Provision. The cost of arbitration may be higher or lower than the cost of bringing a Claim in court, depending upon the nature of the Claim and how the arbitration proceeds. Having more than one Claim and holding a physical arbitration hearing can increase the cost of arbitration.

 

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I called JAMS this afternoon and spoke with a case worker about the filing fee.  The JAMS representative told me they do not get involved with who pays the fee, and would not bill the other party for the fee.

I want to avoid paying the $1,200 filing fee out of pocket because I am pretty certain I'll never see it again.   (This is a non-consumer case.)

Because the arbitration clause reads, " No matter which party initiates the arbitration, we will advance or reimburse filing fees and other costs or fees of arbitration," I thought about filing with JAMS and then sending a letter to the plaintiff to request that they advance the filing fee of $1,200 so we may proceed. 

Any thoughts on this?

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On 10/12/2017 at 9:38 PM, LaneBlane said:

I've been following a case that was brought by the same JDB/OC against someone out-of-state.  The Defendant filed a Motion to Dismiss that listed a few defenses, including lack of standing and the absence of any markers on their contracts showing an e-signature exists.  Their Motion to Dismiss was granted today.

I would be extremely skeptical when people claim to "win" with techniques that have been proven to fail - especially when they appear out of nowhere and have a handful of posts. 

If I'm a debt collector and am losing money to arbitration, why wouldn't I create a "fake" thread saying how easy it was to win in court? Based on your post, it works. 

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I would meet and confirm with the plaintiff attorney and discuss with them the fee and how they will handle that. JAMS is right that it is not their business to bill. Also, that seems a little rich considering others have paid $250.

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1 hour ago, Goody_Ouchless said:

I would be extremely skeptical when people claim to "win" with techniques that have been proven to fail - especially when they appear out of nowhere and have a handful of posts. 

If I'm a debt collector and am losing money to arbitration, why wouldn't I create a "fake" thread saying how easy it was to win in court? Based on your post, it works. 

I definitely agree with you when it comes to threads on forums like this.  I was actually following a court case and was looking at legal documents that had been filed by the court.

If there's one thing I've learned, nothing is easy.

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1 hour ago, WhoCares1000 said:

I would meet and confirm with the plaintiff attorney and discuss with them the fee and how they will handle that. JAMS is right that it is not their business to bill. Also, that seems a little rich considering others have paid $250.

The $250 is based upon JAMS consumer arbitration.  This is a business debt so the consumer rules would not apply and the costs for a business to arbitrate a claim would as this is a business to business claim.

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1 hour ago, WhoCares1000 said:

I would meet and confirm with the plaintiff attorney and discuss with them the fee and how they will handle that. JAMS is right that it is not their business to bill. Also, that seems a little rich considering others have paid $250.

My case involves a business loan, so I'm afraid I won't be able to get by with a $250 JAMS filing fee.  The filing fee for non-consumer is $1,200.

I started to do some research on what may happen when a creditor fails to advance the arbitration fee if the contract calls for it.  In New Jersey, including the NJ Superior Court, failure to advance arbitration fees under a contractual obligation was considered a material breach.  I need to search for case law in Minnesota and the US Supreme Court.

One thing I'm uncertain of is how the term "we will advance or reimburse" can be interpreted.  The contract does not give the creditor discretion over whether they advance or reimburse.  If I demand  they advance the arbitration fees, and they said they would only reimburse, I would take this as a refusal to advance.  The contract doesn't give them the freedom of choice.

Does anyone see this differently?

There is the option of paying the $1,200 filing fee.  Not only will I likely never see this money again, it may also set a precedent that I will pay my own arbitration fees and be reimbursed by the other party.  I feel it's important to establish from the beginning that I expect and demand that the other side advance all arbitration fees and costs.

If I promptly file with JAMS, make a written demand to the other party to advance the fee, and the other party refuses to pay, JAMS would decline the claim and send me a letter to that effect.  This may be enough for me to make a motion with the court to dismiss with prejudice.  (In a perfect world.)

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File it in JAMS as a consumer arbitration.  Don't send any money.  Tell JAMS you have asked the other side to forward your portion of the filing fee per the agreement.

Let JAMS tell you if it is not a consumer case.  Let JAMS figure all of it out.  Stop calling JAMS.  That is the same as talking to a court clerk.  You might as well ask a random person on the subway how JAMS handles payments.  Once you have a case manager, that person will actually know the JAMS rules and can answer questions through email.

You are stuck with JAMS now. Don't derail your own case and just make the best of it.

If BK is an option for you, keep it in the back pocket until the arbitration is fully complete.  I would fight everything along the way to make the best of it.

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I've only contacted JAMS to ask them a couple questions.  The representative I spoke with didn't seem too knowledgeable, so I agree it's like asking a random person on the subway... at about 10:30 P.M.

Tonight I'll start on the paperwork for JAMS and draft a letter to the other side to demand that they advance the fee.  (I won't mention the amount of fee because I'll let JAMS make the determination if it's a consumer case or not.)

Do you have any thoughts on the term "we will advance or reimburse" when it comes to the other side covering the arbitration costs and fees?  I define "we will advance or reimburse" as meaning either because the arbitration agreement doesn't give the JDB the discretion to choose between the two.  I'm uncertain if JAMS will see it the same way.  This is the way I understand the contract because it lacks further detail.

Bankruptcy isn't an option because I have excellent credit and wouldn't want to jeopardize that.  This is the only negative item on my credit reports.  The amount in question is roughly $7,000.  I could settle at 20%.  Otherwise, I'm prepared to come at them with as much as I can possibly find.

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Once you file with JAMS, if you wish to settle, you are free to contact the attorney and offer a settlement. I would start at $1000 and work up to $1400 from there. The attorney might accept the $1000 just to get rid of you.

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1 hour ago, WhoCares1000 said:

Once you file with JAMS, if you wish to settle, you are free to contact the attorney and offer a settlement. I would start at $1000 and work up to $1400 from there. The attorney might accept the $1000 just to get rid of you.

I would start at mutual walk away and work up to $1k from there.

@LaneBlane you are putting way too much into this.  Filing JAMS is the easiest thing to do.  Download the consumer demand form from the JAMS website and the instructions are on the page.  Follow those instructions.  When you send your copy to the JDB, include a cover letter that simply says "Please see the attached JAMS demand form per the court order on XX/XX/2017.  Please forward my portion of the filing fee to JAMS per the contract".  That's it.  That's the full letter.

For your copy to JAMS, I include a copy of this letter to the JDB and I make a JAMS cover letter that simply says "Please see the attached consumer arbitration demand per the order of XYZ Court dated XX/XX/2017. I have requested that the company forward my filing fee per the contract".  That's it. 

Don't forget to include a copy of the granted MTC order from court in both packets.  Then wait for JAMS to contact you.  When you get your case number, you are free to attempt to settle with the JDB.

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1 minute ago, fisthardcheese said:

"Please see the attached JAMS demand form per the court order on XX/XX/2017.  Please forward my portion of the filing fee to JAMS per the contract".  That's it.  That's the full letter.

The only thing I'm overthinking right now is whether or not JAMS will force the other side to advance the arbitration costs and fees.  The arbitration agreement says "advance or reimburse," so I've been trying to get some clarification.  After coming up with an example scenario, I'm sure they will need to advance upon my request.

If a store told you that you could return an item for a refund or an exchange, and you returned the item asking for a refund, they could not tell you they will only exchange it.

I promise this "advance or reimburse" thing was my only hangup.  I'm actually looking forward to getting this thing started.  GAME ON!

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1 hour ago, WhoCares1000 said:

Once you file with JAMS, if you wish to settle, you are free to contact the attorney and offer a settlement. I would start at $1000 and work up to $1400 from there. The attorney might accept the $1000 just to get rid of you.

Thank you for your suggestion.  I've decided to file with JAMS, demand the other party advance the fees, and put the ball in their court.   If they need to advance all the fees and costs, they can make a settlement offer.

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3 hours ago, fisthardcheese said:

Don't forget to include a copy of the granted MTC order from court in both packets.

The Judge instructed me to put an order together for his signature and advised me what it needs to say.  I have a copy ready to take to the courthouse this afternoon.

After the Judge signs this, I can pick up a copy and send it off to JAMS and the Plaintiff, along with the JAMS demand and cover letters.  I'll keep the letters short, just like you recommended.

 

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