MikeS

Being sued by Midland Credit Management and Portfolio Recovery Associates in Ohio

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I'm being sued by both Midland Credit Management and Portfolio Recovery Associates in Ohio. I'm happy to provide the details of both complaints if needed. 

Most of my early reading led me to believe i needed to get my answer filed quickly and not having a default judgement entered against me. I did that and both have been scheduled for a trial date so I have at least made it past the first hurdle. Now that I have been reading more, it seems like arbitration is a very powerful tool for consumers in getting junk debt buyers to stop pursuing the debt. 

My first question is, since I have already filed my answer and I did not list arbitration as a defense am I out of luck in pursuing a MTC arbitration?

Please forgive my follow up questions as I'm still early on in researching arbitration. Please feel free to nudge me toward some reading on these. If I am actually able to file MTC arbitration, what is the end goal? I know that the arbitrators decision is binding. Is the purpose of getting to arbitration that the junk debt buyer drops everything because its not worth their trouble? What do I do if they participate in the arbitration?

Thanks for any help offered. I can provide any additional information about the complaints if requested.

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First who are the original creditors that they bought the debts from?  Some creditors have removed or restricted using arbitration so it is not automatically an option.  Second:  be aware that PRA has currently followed at least two Defendants that we know in to arbitration.  It may not be as big a threat as it used to be.

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29 minutes ago, Clydesmom said:

First who are the original creditors that they bought the debts from?  Some creditors have removed or restricted using arbitration so it is not automatically an option.  Second:  be aware that PRA has currently followed at least two Defendants that we know in to arbitration.  It may not be as big a threat as it used to be.

A simple MTD for lack of subject matter juris is all thats needed if an arb clause exist that waives parties rights to go to court upon demand for arb, no MTC  needed. 

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Both are from Synchrony Bank.  The Midland one is about $1,600 and PRA is about $1,800. 

From my digging around, it appears Synchrony Bank has an arbitration clause, although I dont fully understand all the details. In the PRA complaint, they did me the honor of attaching the card holder agreement as Exhibit C.

Is it best to pursue arbitration for both regardless if they may follow me into arbitration? What other strategies should I pursue otherwise?

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I just checked the court website and see that the PRA filed notice of service for Combined Interrogatories, Request for Admissions, and Request for Production of Documents on the 5th however I have not yet received it.

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40 minutes ago, MikeS said:

I just checked the court website and see that the PRA filed notice of service for Combined Interrogatories, Request for Admissions, and Request for Production of Documents on the 5th however I have not yet received it.

Can ya post a redacted copy of complaint

 

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2 minutes ago, Robby8900 said:

Can ya post a redacted copy of complaint

 

This is the complaint from PRA. I can also add the Midland one as well if you would like. 

Exhibit A is the Bill of Sale with no specific account number mentioned and what looks like an excel spreadsheet with some account data that has no context.

Exhibit B is an Account Statement

Exhibit C is the Credit Card Agreement

 

1. The Plaintiff is the owner of the Defendant's SYNCHRONY BANK - HOME SOURCE account, account number XXXXXXXXXXXXXXXX. The Chain of Title is attached hereto as Exhibit A

2.    By use of the account, the Defendant became bound by terms in the Account's agreement. Copies of the Statements and Agreement are attached hereto as Exhibits B and C.
3.    The Defendant breached the Account's agreement by failing to make payments on the Account as required.
4.    The amount due and owing by the Defendant is $X,XXX.XX.
5.     Although demand has been made upon the Defendant to liquidate the balance due and owing, the Defendant failed to do so.
6.    Plaintiff does not seek an award of attorney fees, contractual or statutory interest after the date of charge off including any post judgment interest, and expressly disclaims any right it may have to the same. 

Wherefore, the Plaintiff prays for judgment against the Defendant in the amount of $X,XXX.XX and court costs. 

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4 minutes ago, MikeS said:

This is the complaint from PRA. I can also add the Midland one as well if you would like. 

Exhibit A is the Bill of Sale with no specific account number mentioned and what looks like an excel spreadsheet with some account data that has no context.

Exhibit B is an Account Statement

Exhibit C is the Credit Card Agreement

 

1. The Plaintiff is the owner of the Defendant's SYNCHRONY BANK - HOME SOURCE account, account number XXXXXXXXXXXXXXXX. The Chain of Title is attached hereto as Exhibit A

2.    By use of the account, the Defendant became bound by terms in the Account's agreement. Copies of the Statements and Agreement are attached hereto as Exhibits B and C.
3.    The Defendant breached the Account's agreement by failing to make payments on the Account as required.
4.    The amount due and owing by the Defendant is $X,XXX.XX.
5.     Although demand has been made upon the Defendant to liquidate the balance due and owing, the Defendant failed to do so.
6.    Plaintiff does not seek an award of attorney fees, contractual or statutory interest after the date of charge off including any post judgment interest, and expressly disclaims any right it may have to the same. 

Wherefore, the Plaintiff prays for judgment against the Defendant in the amount of $X,XXX.XX and court costs. 

Sure

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If you did not reject the arbitration clause then you both parties have waived their right to be in court. i am not an attorney and cant give you legal advice. If it were me personally i would filed a MTD and not a MTC. The one making the claim has to file arbitration after a demand to arbitrate is noticed. I don't know how much simpler than saying if you did not reject the arb clause than neither party has right to move a claim before the court that is subject to arb. A case was just dismissed on this argument without having to go to court for the MSJ hearing. Although it was an objection to the MSJ here in Ohio she didn't have to file an MTC. if you want to read the post and the MSJ and Objection. 

 

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1 minute ago, Robby8900 said:

Sure

This is the complaint from Midland .

The only thing they include in Exhibit A is some account statements. No Bill of Sale or anything else.

I think it's comical that they include 5-8. It's obviously a form and not specific to any individual.

 

1. Plaintiff, MIDLAND CREDIT MANAGEMENT, INC. ("Plaintiff') is a limited liability company qualified lo do business in Ohio. 

2. This court is the proper court because Plaintiff is informed and believes that Defendant, XXXXXXXX (hereafter "Defendant"), residence lies within the jurisdiction of this Court. 

FACTS

3. Defendant opened an account with SYNCHRONY BANK, known by account number XXXXXXXXXXXX-XXXX or its predecessor in interest. A copy of the account statement is attached as Exhibit "A". 

4. Plaintiff has purchased Defendant's debt and is entitled lo all rights as owner thereof. 

MIDLAND'S EFFORTS TO RESOLVE THE UNDERLYING OBLIGATION 

5. MIDLAND CREDIT MANAGEMENT, INC owns portfolios or consumer receivables, which it attempts to collect. When working with individual consumers, MIDLAND CREDIT MANAGEMENT, INC and its affiliates (collectively, "Midland") generally attempt 10 contact consumers like Defendant through several means, all in an effort to establish contact and to resolve the underlying obligation. In doing so, Midland attempts to assess each consumer's willingness to pay, through phone calls, letters or other means. Midland attempts to exclude consumers from its collection efforts, where Midland believes those consumers are facing extenuating circumstances or hardships that would prevent them from making any payments, 

6. When Midland contacts consumers, it strives to treat consumers with respect compassion and integrity. Midland works with consumers in an effort to find mutually ­beneficial solutions, often offering discounts, hardship plans, and payment options. Midland's efforts are aimed at working with the consumers to repay their obligations and to attain financial recovery. Midland strives to engage in dialogue that is honorable and constructive, and to play a positive role in consumers' lives, 

7. Despite Midland's efforts to reach consumers and resolve the consumer's obligations, only a percentage of consumers choose to engage with Midland. Those who do are often offered discounts or payment plans that are intended to suit their needs. Midland would prefer to work with consumers to establish voluntary payment arrangements resulting in the resolution of any underlying obligations, 

8. However, the majority of Midland's consumers ignore calls or letters, and some simply refuse to repay their obligations despite an apparent ability to do so. When this happens, Midland must decide then whether to pursue collection through legal channels, including litigation like the present action against Defendant. Although the account is now in litigation. Plaintiff remains willing to explore a mutually-beneficial solution through voluntary payment arrangements, if possible. 

CLAIM FOR RELIEF 

9. There is now due and owing from the Defendant. the amount of$X,XXX.XX.

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

WHEREFORE, Plaintiff prays for judgment against Defendant as follows: 

a)    For the unpaid balance of $X,XXX.XX, and.

b)    Interest at the statutory rate, per annum, from the date of judgment, and, 

c)    Court costs for suit, and

d)   Such other relief as this Court may deem just and proper.

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2 minutes ago, MikeS said:

This is the complaint from Midland .

The only thing they include in Exhibit A is some account statements. No Bill of Sale or anything else.

I think it's comical that they include 5-8. It's obviously a form and not specific to any individual.

 

1. Plaintiff, MIDLAND CREDIT MANAGEMENT, INC. ("Plaintiff') is a limited liability company qualified lo do business in Ohio. 

2. This court is the proper court because Plaintiff is informed and believes that Defendant, XXXXXXXX (hereafter "Defendant"), residence lies within the jurisdiction of this Court. 

FACTS

3. Defendant opened an account with SYNCHRONY BANK, known by account number XXXXXXXXXXXX-XXXX or its predecessor in interest. A copy of the account statement is attached as Exhibit "A". 

4. Plaintiff has purchased Defendant's debt and is entitled lo all rights as owner thereof. 

MIDLAND'S EFFORTS TO RESOLVE THE UNDERLYING OBLIGATION 

5. MIDLAND CREDIT MANAGEMENT, INC owns portfolios or consumer receivables, which it attempts to collect. When working with individual consumers, MIDLAND CREDIT MANAGEMENT, INC and its affiliates (collectively, "Midland") generally attempt 10 contact consumers like Defendant through several means, all in an effort to establish contact and to resolve the underlying obligation. In doing so, Midland attempts to assess each consumer's willingness to pay, through phone calls, letters or other means. Midland attempts to exclude consumers from its collection efforts, where Midland believes those consumers are facing extenuating circumstances or hardships that would prevent them from making any payments, 

6. When Midland contacts consumers, it strives to treat consumers with respect compassion and integrity. Midland works with consumers in an effort to find mutually ­beneficial solutions, often offering discounts, hardship plans, and payment options. Midland's efforts are aimed at working with the consumers to repay their obligations and to attain financial recovery. Midland strives to engage in dialogue that is honorable and constructive, and to play a positive role in consumers' lives, 

7. Despite Midland's efforts to reach consumers and resolve the consumer's obligations, only a percentage of consumers choose to engage with Midland. Those who do are often offered discounts or payment plans that are intended to suit their needs. Midland would prefer to work with consumers to establish voluntary payment arrangements resulting in the resolution of any underlying obligations, 

8. However, the majority of Midland's consumers ignore calls or letters, and some simply refuse to repay their obligations despite an apparent ability to do so. When this happens, Midland must decide then whether to pursue collection through legal channels, including litigation like the present action against Defendant. Although the account is now in litigation. Plaintiff remains willing to explore a mutually-beneficial solution through voluntary payment arrangements, if possible. 

CLAIM FOR RELIEF 

9. There is now due and owing from the Defendant. the amount of$X,XXX.XX.

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

WHEREFORE, Plaintiff prays for judgment against Defendant as follows: 

a)    For the unpaid balance of $X,XXX.XX, and.

b)    Interest at the statutory rate, per annum, from the date of judgment, and, 

c)    Court costs for suit, and

d)   Such other relief as this Court may deem just and proper.

Same argument can also apply to that suit. those are my sugestions to end it quick. Lack of subject matter jurisdiction if you didn't reject the arb clause. 

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9 minutes ago, Robby8900 said:

If you did not reject the arbitration clause then you both parties have waived their right to be in court. i am not an attorney and cant give you legal advice. If it were me personally i would filed a MTD and not a MTC. The one making the claim has to file arbitration after a demand to arbitrate is noticed. I don't know how much simpler than saying if you did not reject the arb clause than neither party has right to move a claim before the court that is subject to arb. A case was just dismissed on this argument without having to go to court for the MSJ hearing. Although it was an objection to the MSJ here in Ohio she didn't have to file an MTC. if you want to read the post and the MSJ and Objection. 

 

I did not reject any arbitration clause. If i go with a MTD and it were denied would i be stuck without other options? I assume my MTD should be with prejudice?

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13 minutes ago, MikeS said:

I did not reject any arbitration clause. If i go with a MTD and it were denied would i be stuck without other options? I assume my MTD should be with prejudice?

I assume with any moton in a proceeding if denied the case moves forward, however since you didn't reject the arb clause is only in your favor. Of course that would be up to you on how to move forward in your case. but both parties are bound by the written agreement and the arb clause speaks for itself. Hold em to it.

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10 minutes ago, Robby8900 said:

I assume with any moton in a proceeding if denied the case moves forward, however since you didn't reject the arb clause is only in your favor. Of course that would be up to you on how to move forward in your case. but both parties are bound by the written agreement and the arb clause speaks for itself. Hold em to it.

How does this look for my motion? Should i be asking for dismissal with prejudice? I stated that in #2, if i leave it there i probably need to add it in my wherefore section?

 

NOW COMES Defendant XXXX, appearing Pro Se for its Motion to Dismiss for lack of subject matter jurisdiction and as grounds thereto states the following:

 

 

 

1. That on or about XXXXX, 2020, Plaintiff filed its Complaint against Defendant.

 

2. The plaintiff's complaint should be dismissed for this Court's lack of subject matter jurisdiction to render judgment on the merits. Defendant moves this court to DISMISS WITH PREJUDICE based on the terms and conditions of the Credit Card Agreement (see Plaintiff Exhibit C, attached).

 

3. The written agreement is governed by and enforced under the Federal Arbitration Act 9 U.S.C. 1-16 in fact, the defendant did Not reject the arbitration clause, therefore both parties have waived their Right to pursue claims in this Court. The “Arbitration Agreement” states as follows:

 

(a) “DISPUTES BETWEEN YOU AND US WILL BE SUBJECT TO INDIVIDUAL ARBITRATION. THIS MEANS THAT: (1) NEITHER A COURT NOR A JURY WILL RESOLVE ANY SUCH DISPUTE”

 

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

Additionally, this court lacks jurisdiction to render judgment on the merits of claims that are subject to arbitration, HENRY SCHEIN, INC. v. ARCHER & WHITE SALES, INC. 586 U. S. ____ (2019).

 

Ohio Revised Code Section 2711.01(A) states that "A provision in any written contract . . . to settle by arbitration a controversy that subsequently arises out of the contract, or out of the refusal to perform the whole or any part of the contract . . . shall be valid, irrevocable, and enforceable, except upon grounds that exist at law or equity for the revocation of any contract."

 

Ohio public policy favors the enforcement of private arbitration agreements. Kelm v. Kelm (1993), 68 Ohio St.3d 26, 623 N.E.2d 39. See also, N. Ohio Sewer Contrs., Inc. v. Bradley Dev. Co. (2005), 159

Ohio App.3d 794, 2005-Ohio-1014, 825 N.E.2d 650; Junkins v. Spinnaker Bay Condominium assn, Ottawa App. No. OT-01-007, 2002-Ohio-872.

 

 

Any uncertainty that exists with regard to the applicability of an arbitration clause should be resolved in favor of coverage. Id. An arbitration clause should not be denied effect unless it can be determined to a high degree of certainty that the clause does not cover the asserted dispute. Owens Flooring Co. v. Hummel Constr. Co. (2000), 140 Ohio App.3d 825, 749 N.E.2d 782. See also Willis v. Linnen, Summit App. No. 20775, 2002-Ohio-2000. The law favors and encourages arbitration. Brennan v. Brennan (1955), 164 Ohio St. 29, 128 N.E.2d 89.

 

 

 

 

 

WHEREFORE, Defendant, moves this Honorable Court to enforce the written arbitration agreement, and enter an Order dismissing plaintiff's complaint for lack of subject matter jurisdiction.

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17 minutes ago, MikeS said:

How does this look for my motion? Should i be asking for dismissal with prejudice? I stated that in #2, if i leave it there i probably need to add it in my wherefore section?

 

NOW COMES Defendant XXXX, appearing Pro Se for its Motion to Dismiss for lack of subject matter jurisdiction and as grounds thereto states the following:

 

 

 

1. That on or about XXXXX, 2020, Plaintiff filed its Complaint against Defendant.

 

2. The plaintiff's complaint should be dismissed for this Court's lack of subject matter jurisdiction to render judgment on the merits. Defendant moves this court to DISMISS WITH PREJUDICE based on the terms and conditions of the Credit Card Agreement (see Plaintiff Exhibit C, attached).

 

3. The written agreement is governed by and enforced under the Federal Arbitration Act 9 U.S.C. 1-16 in fact, the defendant did Not reject the arbitration clause, therefore both parties have waived their Right to pursue claims in this Court. The “Arbitration Agreement” states as follows:

 

(a) “DISPUTES BETWEEN YOU AND US WILL BE SUBJECT TO INDIVIDUAL ARBITRATION. THIS MEANS THAT: (1) NEITHER A COURT NOR A JURY WILL RESOLVE ANY SUCH DISPUTE”

 

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

Additionally, this court lacks jurisdiction to render judgment on the merits of claims that are subject to arbitration, HENRY SCHEIN, INC. v. ARCHER & WHITE SALES, INC. 586 U. S. ____ (2019).

 

Ohio Revised Code Section 2711.01(A) states that "A provision in any written contract . . . to settle by arbitration a controversy that subsequently arises out of the contract, or out of the refusal to perform the whole or any part of the contract . . . shall be valid, irrevocable, and enforceable, except upon grounds that exist at law or equity for the revocation of any contract."

 

Ohio public policy favors the enforcement of private arbitration agreements. Kelm v. Kelm (1993), 68 Ohio St.3d 26, 623 N.E.2d 39. See also, N. Ohio Sewer Contrs., Inc. v. Bradley Dev. Co. (2005), 159

Ohio App.3d 794, 2005-Ohio-1014, 825 N.E.2d 650; Junkins v. Spinnaker Bay Condominium assn, Ottawa App. No. OT-01-007, 2002-Ohio-872.

 

 

Any uncertainty that exists with regard to the applicability of an arbitration clause should be resolved in favor of coverage. Id. An arbitration clause should not be denied effect unless it can be determined to a high degree of certainty that the clause does not cover the asserted dispute. Owens Flooring Co. v. Hummel Constr. Co. (2000), 140 Ohio App.3d 825, 749 N.E.2d 782. See also Willis v. Linnen, Summit App. No. 20775, 2002-Ohio-2000. The law favors and encourages arbitration. Brennan v. Brennan (1955), 164 Ohio St. 29, 128 N.E.2d 89.

 

 

 

 

 

WHEREFORE, Defendant, moves this Honorable Court to enforce the written arbitration agreement, and enter an Order dismissing plaintiff's complaint for lack of subject matter jurisdiction.

Did they attach a copy of the arb clause as you stated in Plaintiff's exhibit C. my suggestion is that you don't need the following,: 

Ohio Revised Code Section 2711.01(A) states that "A provision in any written contract . . . to settle by arbitration a controversy that subsequently arises out of the contract, or out of the refusal to perform the whole or any part of the contract . . . shall be valid, irrevocable, and enforceable, except upon grounds that exist at law or equity for the revocation of any contract."

 

Ohio public policy favors the enforcement of private arbitration agreements. Kelm v. Kelm (1993), 68 Ohio St.3d 26, 623 N.E.2d 39. See also, N. Ohio Sewer Contrs., Inc. v. Bradley Dev. Co. (2005), 159

Ohio App.3d 794, 2005-Ohio-1014, 825 N.E.2d 650; Junkins v. Spinnaker Bay Condominium assn, Ottawa App. No. OT-01-007, 2002-Ohio

 

 

 

 

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1 minute ago, Robby8900 said:

Did they attach a copy of the arb clause as you stated in Plaintiff's exhibit C. my suggestion is that you don't need the following,: 

Ohio Revised Code Section 2711.01(A) states that "A provision in any written contract . . . to settle by arbitration a controversy that subsequently arises out of the contract, or out of the refusal to perform the whole or any part of the contract . . . shall be valid, irrevocable, and enforceable, except upon grounds that exist at law or equity for the revocation of any contract."

 

Ohio public policy favors the enforcement of private arbitration agreements. Kelm v. Kelm (1993), 68 Ohio St.3d 26, 623 N.E.2d 39. See also, N. Ohio Sewer Contrs., Inc. v. Bradley Dev. Co. (2005), 159

Ohio App.3d 794, 2005-Ohio-1014, 825 N.E.2d 650; Junkins v. Spinnaker Bay Condominium assn, Ottawa App. No. OT-01-007, 2002-Ohio

 

 

 

 

Yes, they included the entire agreement as part of the complaint. Do you have any thoughts on with prejudice, without prejudice, not specifying at all?

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The lady that won her case this week did with prejudice but the judge dismissed case without prejudice. 

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5 minutes ago, Robby8900 said:

The lady that won her case this week did with prejudice but the judge dismissed case without prejudice. 

So it wouldn't hurt to ask for dismissal with Prejudice? The judge can always just dismiss without prejudice? Forgive me if this is a dumb question.

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4 minutes ago, Robby8900 said:

of course, who wouldn't want it dismissed with prejudice. 

One more question for now.

When I receive "PLAINTIFF'S FIRST SET OF INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSIONS" do I need to do anything with those or should I leave it alone until my motion is addressed?

The certificate of service in the court website says it was served June 5 but I have not yet received it.

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37 minutes ago, MikeS said:

One more question for now.

When I receive "PLAINTIFF'S FIRST SET OF INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSIONS" do I need to do anything with those or should I leave it alone until my motion is addressed?

The certificate of service in the court website says it was served June 5 but I have not yet received it.

I would suggest that discovery is reserved upon the plaintiff's claims entering arbitration puersuant the written agreement. 

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18 minutes ago, Robby8900 said:

I would suggest that discovery is reserved upon the plaintiff's claims entering arbitration puersuant the written agreement. 

Ok. I plan to file tomorrow unless anyone else has something else to add prior to me doing so.

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Just now, MikeS said:

Ok. I plan to file tomorrow unless anyone else has something else to add prior to me doing so.

Motion to dismiss for lack of subject matter jurisdiction. Don forget certificate of service,  

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1 hour ago, MikeS said:

MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION;      i personally would remove the "Magistrate'' name replace with judge 

Additionally if it were me personally, i would remove the entire paragraph above the Wherefore clause, its not needed. your not trying compel arb with this motion its about dismissal regarding the fact you didn't reject the arb clause, therefore, waiving the rights to be at the court. The plaintiff's claims ar subject to arbitration, there the court cannot render judgment be cause 1) both parties right to go to court has been waive by you not rejecting the clause and 2) claims subject to arb, a court has no business ruling on the merits and 3) the arb clause must be enforced as written. its written that you if you dont reject then court is waived that simple. But you can always run into a hard head judge.  

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