SHELLY7

Midland Funding Suing In NY

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On 2/13/2019 at 1:33 PM, SHELLY7 said:

just out of curiosity @fisthardcheese though it's obvious I know nothing about nothing, how long would you give it until you filed a MTC if they didn't follow through, obviously not ten years but I'm just wondering in a general sense the time frame.

Also, in my research I've been looking up motion for arbitrations so I can follow them to the letter if need be (and obviously yours too;)

Do you think its a good format where they kind of do it like this:

https://turtletalk.files.wordpress.com/2017/05/11-1-motion-to-compel-arbitration.pdf

This whole huge memorandum where they go through facts/history etc or is it better to keep it kind of short and sweet? Just a general question I know and of course my case wouldn't be as long I'm just trying to get everything perfect and the nerd in me really wants an A so to speak..

After the court grants your MTC, you will file a case with JAMS and then you wait what could be up to 90 days for either Midland to ask to dismiss the case or for JAMS to close the case due to Midland not paying and then you go back to court at that time and ask for sanctions and a dismissal. I wouldn't wait at all once they violate the court's order to arbitrate.

Your MTC does not have to be as long or complex as one an attorney has written.  The Judge will know you are representing yourself and will not expect your motion to be exactly as precise and wordy.  All you need to do is convey the main points and case laws to back up your points.

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copy that @fisthardcheese I'm like you, I like to know EXACTLY how long for everything lol (obviously) once they file the RJI (god knows when or if they will) but I'll have my MTC ready thanks to all of you. And thanks for explaining everything since this is so evidently my first rodeo;)

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Hi Guys. I finally got officially "served" today....I've obviously been preparing my court answer and also MTC per everyone's SUPER helpful suggestions. I have a question though...probably more specific to @usctrojanalum (because NY specific) I have been evidently researching like crazy, and I know that you can "mail and nail" the summons and complaint and still something has to come in the mail and also from the court (for Suffolk county NY at least.)

Obviously, those things or steps still have to happen, but I know you can besides the general denial write that papers weren't properly served. Am just wondering, the dude just left my printed out summons and complaint in the door handle of my front door. Can he do this on a public holiday? Since the courts aren't in session today because of president's day? Just wondering....if I should add that or if it's really of no relevance since perhaps the plaintiff can just get an extension or such and I'm back where I started and don't want to muddy the waters so to speak or have to go back to the beginning. Just curious your thoughts and thanks again for all and everyone's help!

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Fighting effective service, even if there was a technical service error, is a pretty big waste of time and energy when all they have to do is serve you again.  I would instead spend my energy on the sure win strategy.

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Thanks @fisthardcheese I figured so much and honestly, just want to fight this and get it over with...I just didn't want that lingering in my mind.  I have a question for you though, since I have you here, is there anything they can use against me if you deny all their allegations (in the answer to court) but then do file a motion to compel arbitration? I'm just doing my court answers so I can post here and then obviously focus on my motion so I can also impede on your kind graces...I just don't want to do anything in my answer that they could use against me if I tried for a motion to compel arbitration. For instance like on number 4 and 5 it says:


4. Raintiff's predecessor  in interest, (hereinafter "Origind Creditor"),
offered to open a -branded account, account no. ending in (hereinafter the "Account"), in Defendant's name on  subject to the terms and conditions provided, or made available in electronic format, to the Defendant (the "Agreement").

5. Defendant accepted the offer by using the Account.

If I deny these allegations (in my court answer) and then try to do a motion to compel arbitration, can they use that by saying oh no you said you didn't use the account or what have you? Not sure if I'm making sense...just want to make sure my court answers can't be used against me later on I guess...

Thanks again for your time everyone. I would literally be a sinking ship of despair without all of you, gratitude doesn't even begin to cut it...

 

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19 minutes ago, SHELLY7 said:

Thanks @fisthardcheese I figured so much and honestly, just want to fight this and get it over with...I just didn't want that lingering in my mind.  I have a question for you though, since I have you here, is there anything they can use against me if you deny all their allegations (in the answer to court) but then do file a motion to compel arbitration? I'm just doing my court answers so I can post here and then obviously focus on my motion so I can also impede on your kind graces...I just don't want to do anything in my answer that they could use against me if I tried for a motion to compel arbitration. For instance like on number 4 and 5 it says:


4. Raintiff's predecessor  in interest, SYNCHRONY BANK (hereinafter "Origind Creditor"),
offered to open a PAYPAL-branded account, account no. ending in 4946 (hereinafter the "Account"), in Defendant's name on July 29, 2005, subject to the terms and conditions provided, or made available in electronic format, to the Defendant (the "Agreement").

5. Defendant accepted the offer by using the Account.

If I deny these allegations (in my court answer) and then try to do a motion to compel arbitration, can they use that by saying oh no you said you didn't use the account or what have you? Not sure if I'm making sense...just want to make sure my court answers can't be used against me later on I guess...

Thanks again for your time everyone. I would literally be a sinking ship of despair without all of you, gratitude doesn't even begin to cut it...

 

It's not like you are chiseling your answer in stone and forming a blood pact.  You can, and people do, change their answers as the case progresses and more evidence is presented.  It is standard procedure to initially deny everything, especially a compound paragraph that makes several conclusions or allegations in one sentence such as #4.  The answer is just an instrument to avoid default.  Don't put too much focus or stress into it.

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ok thank you @fisthardcheese I think I am overthinking so will pull back a little lol. REALLY appreciate you getting back to me! 

I suppose I keep thinking anything you say can be used against you in a court of law, like when people get arrested on tv sigh.

Thanks again, promise to stop pestering and hope you enjoy your day off if you are taking the day off!

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Raise the issue of service in your answer.

There is a good reason for this. If you get the case dismissed, and they reserve you a second time, if they voluntarily dismiss the second action it operates as with prejudice.

If the service is good anyway, it's not a big deal that you raised it.

Only drawback is, you have to make a motion to dismiss on that ground within 60 days or the defense of lack of service is waived. Handling multiple motions can get tricky/expensive. 

In NY, can serve any day of the week except for Sunday.

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mmmm but it seems they can serve me any day (as in today a court/public holiday), so I guess maybe the service thing doesn't work and I think that would honestly just confuse ME more lol, but thanks for input and always being so patient. Will post my court answers for you to check in a couple days and so appreciate your help always. @usctrojanalum

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Hi Team

Still working on my answers, and of course overthinking as I am an expert at and also, getting too far ahead of myself, which I know is annoying for everyone on here.  So apologizes in advance. But,  I have a quick question though, I was wondering my first affirmative defense Lack of subject matter jurisdiction.  The underlying contract for the alleged debt contains a private arbitration clause and defendant has chosen arbitration as the forum for this dispute, therefore, this Court lacks subject matter jurisdiction.

But, here is my question and totally owning getting ahead of myself...it says in my paypal (synchrony bank) you must notify the other party in writing in their arbitration clause:

 

  1. The party who wants to arbitrate must notify the other party in writing. This notice can be given after the beginning of a lawsuit or in papers filed in the lawsuit. Otherwise, your notice must be sent to Synchrony Bank, Legal Operation, P.O. Box 29110, Shawnee Mission, KS 66201-5320, ATTN: ARBITRATION DEMAND. The party seeking arbitration must select an arbitration administrator, which can be either the American Arbitration Association (AAA), 1633 Broadway, 10th Floor, New York, NY 10019, www.adr.org, 1-800-778-7879, or JAMS, 620 Eighth Avenue, 34th Floor, New York, NY 10018, www.jamsadr.com, 1-800-352-5267. If neither administrator is able or willing to handle the dispute, then the court will appoint an arbitrator.

So after I file an answer should I write the lawyer listed on my summons and complaint and tell him I elect for arbitration? Could this help or hinder me or no? Just trying to follow the rules and get everything correct like the nut job I am and since that's stated I just wondered if I should do that after I file my answer, even though it's done electronically...but since it says "must notify" other party in writing...

Thanks again guys I really would be so lost I can't imagine life without this forum lol

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thanks @usctrojanalum sorry but where should I put this in my answer "papers filed in the lawsuit"-where I write elect arbitration in my affirmative defense? 

I found this on here should I put this then as my first affirmative defense and send a letter to their lawyer this week since I have time, or is that tipping him off too much...I still have 20 days so have ample time to be strategic, hence my over thinking and stalking this poor forum and its members like a loon...

That the Court lacks jurisdiction over the person of the Defendant as Defendant states there is an arbitration clause in the cardholder agreement that takes away both parties litigation rights if elected by either party. Defendant has already notified Plaintiff and Plaintiff's attorney of her election to arbitrate pursuant to the terms of said agreement.

 

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1 hour ago, usctrojanalum said:

Do both. Put it in your answer the "papers filed in the lawsuit" and send a demand.  

Why?

When I file the MTC and send a copy to the attorney for the JDB I am then "notifying them in writing" that I elect arbitration.  I don't see the need for extra steps.

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29 minutes ago, fisthardcheese said:

Why?

When I file the MTC and send a copy to the attorney for the JDB I am then "notifying them in writing" that I elect arbitration.  I don't see the need for extra steps.

Better to be over-inclusive than under inclusive. 

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I think I'll just put arbitration in court answer and then when I submit my answer to court I will send their lawyer a written letter....perhaps I can then include that in my MTC as part of my stance then that I did inform the "other party in writing"

Perhaps thats a middle ground and thanks again guys for input @fisthardcheese @usctrojanalum sorry for always taking up so much of your time

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1 hour ago, fisthardcheese said:

Why?

When I file the MTC and send a copy to the attorney for the JDB I am then "notifying them in writing" that I elect arbitration.  I don't see the need for extra steps.

Fist, I think you raise an important issue of the diversity in the views of judges on compelling a party to arbitrate. We've seen posters who have judges who will not sign a proposed order to compel, but rather order a continuance so that the (pro se) movant can in fact intiate a claim with AAA or JAMS; the view is that the movant has failed to initiate prior to filing the motion. Some judges have held this view even when the arb clause expressly states that the (plaintiff) party refusing to arb must file the claim. One recent poster--after reading to the judge that section of the arb clause--had the judge say, "It doesn't work that way." This begs the question: exactly when is it appropriate, in some judge's opinion, to deem a party has refused to arbitrate after a proper demand notice and must be compelled to do so? 

In my state's court rules, a movant is required to first seek concurrence with the adverse party prior to filing the motion. If the adverse party won't stipulate to the motion's proposed order, the movant has to include language in the motion that concurrence was sought and denied, or a failure to respond was deemed a refusal. 

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Yes, I see what you are saying @Brotherskeeper I suppose in many aspects it is a bit of roll the dice and this is kind of why I guess I take something that is seemingly easy (as in answering my summons and complaint) and read a little too much into everything. That being said, I know that NY can be quite "pro arbitration" but it depends on the judge etc. Also, I believe I mentioned that a judge recently moved that you can't even make a motion to arbitrate until the "non-movant initiates litigation"

https://fhnylaw.com/court-holds-motion-compel-arbitration-cannot-made-non-movant-initiates-litigation/

Then I completely understand @fisthardcheese argument of filing the motion with you answer, but in NY, in my county you have to file $95 for RJI and then file $45 for the motion. It seems, especially like what @usctrojanalum has stated it's not really normal for a defendant to pay the $95, yet rather to wait for the plaintiff to file and then (at least in my mind) I planned on filing the motion to compel as per that judge's instructions.  So it is this bizarre bit of a waiting game which compels me to too much time to read into things I suppose like the "send it writing" clause in my original CC arbitration clause and then I just get tripped up with the shoulds etc.

Luckily, everyone has been so patient with me and offered endless help and I guess in the long term it just comes down to if I make a good enough MTC and if that judge sees my point an I've done everything correctly in the first place. I so so so appreciate everyone weighing in. I promise to not read too much further into everything lol

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@SHELLY7 I think it's wise and advisable to focus on understanding your rules, NY law and legal process. and local court customs as much as possible before taking any action. This is very hard to do while terrified. Once the initial terror subsides, you then are left to learn what amounts to a new language and immediately employ it in a forum where the stakes are very high for you. I'm not familiar with NY, but @usctrojanalum is, and although a busy law school student, is so kind to offer assistance. 

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agreed @Brotherskeeper I am not as terrified as once was, and have been really acquainting myself with NY law, probably one of the reasons I've gone in circles a little bit TOO much reading and researching into things. I will just focus on the tasks at hand and get everything ready as best I can for the "ifs and whens."

And yes, @usctrojanalum is a saint. When I was a student I was much more concerned with which bar I would go to instead of helping crazy loons like myself on a forum.

I shall leave everyone in peace now to just get my answers right and have my MTC ready for the if and when and try to not read so much into everything.

Thanks again everyone for your time, always.

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21 hours ago, Brotherskeeper said:

In my state's court rules, a movant is required to first seek concurrence with the adverse party prior to filing the motion. If the adverse party won't stipulate to the motion's proposed order, the movant has to include language in the motion that concurrence was sought and denied, or a failure to respond was deemed a refusal. 

This is why I was asking @usctrojanalum why he suggested that.  Unless it is a court requirement, I just like keeping things more simple and streamlined for people who are just learning about all of this for the first time and may be overwhelmed with it all.

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Yes. I hear you @fisthardcheese and @usctrojanalum has been beyond patient with pesky me. That being said, though he is no doubt a NY law genius he self-admittedly it's as familiar with arbitration laws in NY.. so much of what I have been doing I have been researching myself probably a little TOO much and as per @Brotherskeeper suggestion to get acquainted with NY laws. I did learn as per @Brotherskeeper suggestion to look up NY law for when to make a motion I did find and under CPLR 7503 "a party must be aggrieved by the failure of another to arbitrate" and a Justice recently ruled that to be "aggrieved" and thereby have standing, a party must be subject to litigation BEFORE filing a special proceeding to compel arbitration (SO I figured THAT much out, I am indeed AGGRIEVED lol) and @usctrojanalum let me know that I've officially entered litigation when I give my answer so I know THAT much and probably aggrieving too many people on here (sorry guys)...  my question is...

In my incessant research I did find that one of the arbitration laws in NY (article 75 of the New York civil practice) states "that 20 days after being notified of an intent to arbitrate if no objection is raised they cannot later object that a valid agreement to arbitrate..."

So in my little mind, I thought it WOULD make sense to send a demand letter when I do my answers to court to midlands attorney stating that I elect arbitration. (Then I could use this in my MTC and if he didn't answer (in 20 days) use that against him too.)

So this leads me again, to a question of the day!!!!

If I were going to send a letter to Midland's attorney (a demand for arbitration letter) can it be as simple as:

This letter is in response to your summons and complaint.  This matter remains in dispute and I hereby demand my election to arbitrate.  Regarding the collection of the account referenced above, the agreement states

  1. The party who wants to arbitrate must notify the other party in writing. This notice can be given after the beginning of a lawsuit or in papers filed in the lawsuit. Otherwise, your notice must be sent to Synchrony Bank, Legal Operation, P.O. Box 29110, Shawnee Mission, KS 66201-5320, ATTN: ARBITRATION DEMAND. The party seeking arbitration must select an arbitration administrator, which can be either the American Arbitration Association (AAA), 1633 Broadway, 10th Floor, New York, NY 10019, www.adr.org, 1-800-778-7879, or JAMS, 620 Eighth Avenue, 34th Floor, New York, NY 10018, www.jamsadr.com, 1-800-352-5267. If neither administrator is able or willing to handle the dispute, then the court will appoint an arbitrator. 

Pursuant to the cardholder agreement, I ELECT arbitration via JAMS to resolve our disputes.

Something to that degree and do I ask the attorney to have it dismissed or am I just straight up demanding (I suppose I should look for demand letter examples on here)...I guess my question is how much needs to go into the "demand letter" thats my question of the day lol 

Thanks again team, immensely 

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Hi Guys, this may seem like world's stupidest questions so I apologize for the millionth time, and I KNOW like @fisthardcheese said, it's not like my court answers are carved in stone...yet still I want to make sure I get everything RIGHT. And am also aware that I overthink, so am saying sorry for that too ahead of time.

So my first question is, in answering the summons and complaint there is a section that says "facts" 

Example here of the first fact:

4. Plaintiff's predecessor in interest,  (hereinafter "Original Creditor")...(then it goes on...)

My question is in my answer do I say (and this may seem so obvious to some) but do I say

Defendant denies any knowledge or information sufficient to form a belief as to the allegations set forth in Paragraph 4 of Plaintiff's Complaint? Or do I write Plaintiff's Facts? (since it's in the fact section.) sorry seems idiotic, I just wasn't sure.

Second question, when I do my answers if I say something like "demands strict proof thereof...." is that confusing things because all proof or discovery should be shown in arbitration so muddies the water and I should stick just with Defendant denies any knowledge of kind of answer and not ask for any sort of proof, or that doesn't really matter either...

Third question, must my affirmative defenses be in any particular order (am obviously starting with lack of subject matter jurisdiction.  The underlying contract for alleged debt contains a private arbitration clause...) but then do the rest of the order matter?

And last question, in my demand letter that I send to their attorney demanding arbitration (since my cc agreement states it must be done in writing) do I demand arbitration and ask that they withdraw the case from court? In my over research I read you must give the opposing party some sort of action or something er other. I don't know, I just always worry when you start sending things to attorneys if you don't do it perfectly maybe they'll use it against you later; ever the fearful one I am, admittedly.

Those are my questions, which I am sure seem dumb to most, just don't want to mess anything up that could hurt me in the future. SUPER beyond words appreciate EVERYONE'S time and help and honestly honestly thank you so much.

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Hi Guys! I finally must give my answers, I've pasted below their summons and complaint (trying to take out my personal info;) per @usctrojanalum suggestion since I always over share lol and then pasted my answers after for your amazingly helpful wondrous kind people's review;)

I am not sure if my Affirmative Defenses are correct, I know the first one is the most important (for arbitration) but just want to make sure I haven't left anything out, as I know sometimes if you don't put them in you they can be waived. Also, the Prayers for relief? I'm wondering if you could peep over as those really confused me lol and I wanted to make sure I got them right. Thanks again everyone for all of your help and then some!

SUMMONS AND COMPLAINT:

            Plaintiff, by its attorneys, complaining of the Defendant(s), respectfully alleges that:

 

1.    Plaintiff is a foreign limited liability company licensed to transact business in New York.

2.    Upon information and belief, the Defendant(s) resides or has an office in the county in which this action is brought, or the Defendant(s) transacted business within the county in which this action is brought, either in person or through an agent and the instant cause of the action arose out of said transaction.

3.    Based upon a reasonable inquire, the Statue of Limitations for the cause of action asserted herin has not expired.

FACTS

4.    Plaintiff’s predecessor in interest, (hereinafter “Original Creditor”), offered to open a L-branded account, account no. ending in    (hereinafter the “Account”), in Defendant’s name on  subject to the terms and conditions provided, or made available in electronic format, to the Defendant (the “Agreement”).

5.    Defendant accepted the offer by using the Account.

6.    Defendant defaulted by failing to repay the Account balance.  The Defendant’s last payment was received on or about n the amount of       .

7.    Demand for payment of the Account was made on Defendant, but Defendant failed to make all the required payments, and as a result the Account was charged off on in the amount of         .

8.    The Original Creditor sold the Account, including all right, title and interest in and to the outstanding balance owed by Defendant.  Plaintiff purchased the Account on or about and is now the owner and assignee of the Account.  The full chain of the assignment of this claim is as follows:

 

AS AND FOR A FIRST CAUSE OF ACTION

9.     Plaintiff repeats and re-alleges each and every allegation contained in the foregoing paragraphs as if more fully set forth herin.

10.   As a result of Defendant’s breach of the Agreement, and after crediting Defendant for all payments and credits, there is now due and owning by Defendant to Plaintiff the sum of          , no part of which has been paid despite due demand therefor.

 

WHEREFORE, Plaintiff demands judgement against Defendant(s) in the amount of                                                                 together with costs and disbursements.

The undersigned attorney hereby certifies that, to the best of his/her knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the within complaint and the contentions therein are not frivolous as defined in part 130-1.1 (c) of the rules of the Chief Administrator.

MY ANSWERS:

 

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPAINT ON ACCOUNT

      DEFENDANT,          ,answering Pro Se, without waiving any affirmative defense, as and for an Answer to Plaintiff’s Complaint, state the following upon information and belief:

 

1.    Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set forth in Paragraph 1 of Plaintiff’s Complaint.

 

2.     Defendant admits the allegations set forth in Paragraph 2 of Plaintiff’s Complaint.

 

3.    Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set for in Paragraph 3 of Plaintiff’s Complaint.

 

FACTS

 

4.     Defendant denies any knowledge or information sufficient to form a belief as to any of the allegation set forth in Paragraph 4 of Plaintiff’s Complaint.

 

5.    Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set forth in Paragraph 5 of Plaintiff’s Complaint.

 

6.    Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set forth in Paragraph 6 of Plaintiff’s Complaint.

 

7.    Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set forth in Paragraph 7 of Plaintiff's Complaint. 

 

8.    Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set forth in Paragraph 8 of Plaintiff's Complaint.t

 

AS FOR A FIRST CAUSE OF ACTION

 

9.     Defendant denies any knowledge or information sufficient to form a belief as to any of the allegations set forth in Paragraph 9 of Plaintiff’s Complaint.

 

10.   Defendant denies any knowledge or information sufficient to form a belief as to any of the allegation set forth in Paragraph 10 of Plaintiff’s Complaint.

 

AFFIRMATIVE DEFENSES

 

11.     Lack of subject matter jurisdiction.  The underlying contract for the alleged debt contains a private arbitration clause and defendant has chosen arbitration as the forum for this dispute, therefore, this Court lacks subject matter jurisdiction.

 

12.     Failure to state a claim upon which may be granted.

 

13.    Defendant denies the amounts claimed by the Plaintiff.  Defendant demands Plaintiff verifies a detailed accounting of all alleged charges and credits to alleged account.

 

14.  The plaintiff is not in control of the necessary documents or witnesses needed to prove the claims.

 

15..    Plaintiff is not an Assignee for the purported agreement and no evidence appears in the record to support any related assumptions.

 

16..    Lack of standing.

 

17.    Failure of consideration.

 

18.    Plaintiff is barred under the Fair Debt Collection Practices Act, and other relevant federal and state statues, from collecting any interest and any amount unless it is expressly authorized by the agreement creating the alleged debt or permitted by law. Plaintiff has failed to attach proper documentation to verify such interest is permitted. 

 

19.    Defendant reserves the right to amend this answer and to assert any affirmative defenses that become known or available.

 

PRAYER FOR RELIEF

 

WHEREFORE, the defendant’s pray for relief from this honorable court as follows:

 

A.    That the Plaintiff takes nothing by way of this Complaint,

 

B.    To dismiss the Complaint with prejudice based upon the admissions, denials, and defenses alleged herin,

 

C.    To award the Defendants’ costs, and

 

D.   To award the Defendant such other and further relief as this Court deems just and equitable

 

 

Respectfully submitted

 

 

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5 minutes ago, fisthardcheese said:

If it were me, I would remove 12 - 19.

really? I'm such a novice? I thought it you didn't state affirmative defenses you couldn't use them later?

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