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16  Flordia Debtor / Post a Question / Re: Unifund has filed against me on: November 23, 2008, 06:02:44 AM
Some basic legal constructs: personal jurisdicton and subject matter jurisdiction.

Both are essential elements for a plaintiff to be able to authorize the courts to act against the sued party.

A breach of contract type law suit does provide subject matter jurisdiction to the courts since it is of the type of cases the FL courts are authorized to adjudicate on. So SMJ is a given.

To obtain personal jurisdiction for a money judgment lawsuit in FL, the plaintiff has to obtain personal service on the defendant, which means that have to personally serve you or a member of your family at least 15 years of age at your normal place of abode.

Absent that, no personal jurisdiction .... except if you become aware of the case by other means.

If you show up in the case, all you can do is quash the illegal service and force them to reserve you in accordance with the law.

If you don't show up in the case, and they obtain default judgment without lawful personal service, then that judgment is void from the start.

Why? Lack of Due Process. You weren't given notice and opportunity to be heard. It's called fraud upon the court.

You can simply file a collateral lawsuit to vacate the void default judgment. Case disposed of.

The problem is that a process server filed an affidavit saying you were served.

You have the burden of proof to prove that process server wrong with the process server having the presumption of correctness.

Focus on the affidavit of service filed in the case and the date/time/place claimed that you were served. 

If you can conclusively prove that you were elsewhere at that date/time/place then you can disprove the process server's affidavit.

 
 

 
17  Flordia Debtor / Post a Question / Re: New to site: Process server trying to serve me with papers from Crap One on: October 02, 2008, 10:49:53 AM
Thanks for the responses. Right now it is just reported on my credit report as a charge off. They are trying to serve me with notice to appear for a pre trail/mediation, but their goal is for a judgement to go on my credit. It only charged off last year. The balance is equal to $3k between 2 credit cards with them. I was told if I just avoid the server until I move in January then they can't put a judgement on my credit because I was never served and given a chance to dispute it in court. Any truth to that? Also what the rules around wage garnishment in FL. I'm 24 and have no assets other than my income.

Just service alone does not get them a judgment.
They have to serve you and either you default by not replying with a answer in defense or you do answer and the case is decided in their favor.
Look at this site on the FL case section and look over the cases involving service of process.
In FL, they can't just drop the paper at your door and have that constitute service.
They must serve process at your 'normal place of abode' to you or a family member at least 15 years of age.
If you or any family member 15 years or older are not home when they attempt service, then service can not be made.
If you are at home, it is best to not be doing anything that could be detected as someone being home.
 
18  Flordia Debtor / Post a Question / Re: Plaintiff's motion for summary final judgment and attorney's fee on: September 10, 2008, 02:54:36 AM
Also, the Summary Judgment rule, 1.510, requires that all affidavits must be made from personal knowledge.
Only an affidavit from an original creditor record custodian would be made from personal knowledge, not from some JDB third party.
A showing of Lack of Personal Knowledge in their affidavit defeats their SJ.

Noting the FDCPA violation of a JDB filing a time barred case is irrelevent to the SJ issue unless you filed a FDCPA counterclaim and move for SJ on that claim.

A complaint cannot be dismissed with a SoL defense before trial unless the plaintiff's own pleadings and evidence show that the SOL has expired.
If that is the case, then you can file a Defendant's Motion for Summary Judgment.


19  Flordia Debtor / Post a Question / Re: Plaintiff's motion for summary final judgment and attorney's fee on: September 10, 2008, 02:39:05 AM
Here is the Motion to Dismiss, What do you think?Huh??


COMES NOW, defendant HuhHuhHuhHuh, pro se and request Plaintiff to answer under oath the following interrogatories.

1. Plaintiff filed the above complaint with the Clerk of Court, Quincy In Gadsden County Florida.
2. Plaintiff failed to state a claim upon which relief can be granted.  No triable issues exist because all of the Plaintiff’s actions are precluded by the Statute of Limitation.  New Hampshire R.S.A. 508:4.  By the Plaintiffs admission of said agreement which states this contract is governed by the State of New Hampshire.  New Hampshire R.S.A. 508:4
3.  Plaintiff’s attached written evidence is incomplete to establish liability.  Oral testimony and/or Parol Evidence will be required to make complete the showing of any alleged legal liability incurred by defendant.  As such their claims are governed by the three year statute of limitations for the state of New Hampshire.
4.  Plaintiff was aware that this alleged debt was precluded by the Statue of Limitations when they filed their case.
5. The following facts apply:
    a. The Plaintiff is primarily in the business of purchasing previously defaulted consumer debt that has already been charged off.
   b. the original alleged creditor, Providian National Bank, sold defaulted debt after it had been charged off.
   c. Plaintiff bought the debt after the charge-off date.
6.  Florida Rule of Civil Procedures 1.130(a) provides that all contracts or documents upon which action may be brought… shall be incorporated in or attached to the pleading.
    a.  “Courts not write exceptions into statutes when the legislature has not” Federal Ins. Co v Southwest Florida Ret. Ctr. Inc, 707 So.2d 1119 (Fla 1998)
6. In the complaint, the Plaintiff is suing the defendant for Breach of Contract/Collection  alleging that defendant is in default of an alleged credit agreement.  The Plaintiff has failed to submit into evidence documentation that supports the claim, Florida Small Claim Rule 7.050 (1).  The written evidence “agreement” attached to the complaint does not indicate an account number, account holder, any amounts of date of breach of contract, this causes the “agreement to by anonymous.  ARDC CORP v Hogan 656 So.2nd 1371 (Fla./ App. 4th District 1995). Furthermore, in paragraph 5 of the complaint, Plaintiff clearly alleges that the defendant “Failed to make payments when due”  but gives no supporting evidence or dates to indicate such.
7. The Plaintiff has or should have expert knowledge of the requirements for their claim and should have taken steps to insure they had the written evidence required for the five year Statue of Limitations , F.S. ss95.11 (2), before filing their complaint.  Where a complaint is based on written instrument, the complaint does not state a cause of action until the instrument or an adequate portion thereof is attached to or incorporated in the complaint.
8.  The Plaintiff has or should have expert knowledge know that the “agreement” entered stated that the State of New Hampshire governs all action pertaining to said agreement.  N.H. R.S.A. 508:4
9.  Plaintiff and the Plaintiff’s counsel are engaging in intrinsic fraud since they knew their action was not founded on a written instrument when thy filed their claim.
10.  It is an FDCPA violation to file an action on a time-barred debt.
   a. Kimber v. Federal Financial Corp. (M.D. Ala. 1987) 668 F.Supp. 1480
Kimber argues that… to collect on a bedt that appears time-barred… constitutes an unfair and unconscionable practice offensive to SS 1692f. the court agrees with Kimber.
11. The Plaintiff failed to submit into evidence any documentation as requested by the production of document entered by the defendant.  The Plaintiff failed to answer to the Interrogatories Propounded to the Plaintiff by the defendant. 
12.  Plaintiff is knowingly attempting to take unfair advantage of both the Defendant and the Court.
13.  A motion to dismiss is proper and justified.
   a. “the defense of statute of limitation may be raised by a motion to dismiss where its violation appears on the face of the complaint or exhibits.” Fla. R. Civ. P. 1.110(d), 1.140 (Toledo Park Homes v. Grant, 447 So. 2d 343, 344 (Fla. 4th DCa 1984)

Wherefore, the Defendant prays that Plaintiff’s action be dismissed in its entirety with prejudice for failure to state a claim upon which relief may be granted.
 


You have to follow the civil procedure governing the case, either small claims or the regular civil procedure.

A motion to dismiss must either be done as a preliminary motion or at trial.
The proper procedure in response to a plaintiff's motion for summary judgment is an Opposition motion to the Plainttiff's Summary Judgment.
You can also file a Defendant's Summary Judgment Motion if you can prove conclusively that the Plaintiff cannot prevail.
Rule 1.510 governs Summary Judgment. Focus on Rule 1.510.
The PLTF flagged rule 1.510 in their SJ motion.


I provided tons of FL Summary Judgment case law in the Florida Case Law section of this website.
Read it!!!
You should use that case law to authorize your motion.

There is a time limit to file an SJ Opposition motion and it is governed by rule 1.510. Focus on Rule 1.510.

You must file an SJ Opposition motion prior to the PLTF's SJ hearing!!!!!

The bottom line is that in order to obtain SJ, the PLTF must prove their case conclusively.
Any doubt precludes SJ.
Since you raised a SOL defense, the burden is on the PLTF to defeat that defense in order to obtain SJ.
I saw nothing that shows that they have done that.
Therefore, as a matter of law, their SJ motion should be denied.

Since this case sat for more than a year, you should have motioned to dismiss for want of prosecution one year and one day after the last action in the case which would apparently have been in the late fall of 2007.

They are trying to sneak this by you hoping you're asleep at the wheel.

You must file an SJ opposition!!!

 


20  Flordia Debtor / Post a Question / Re: NCO calling me at work - Need help on: August 07, 2008, 01:47:26 PM
Thanks for the link. I've been reading the info but there are a few things I don't understand. The Homestead Exemption in Florida... is that a form you need to fill out? Is it the same form that you fill out for the taxes? Are you automatically protected or you need to have the form filled out?


To exercise your FL Constitutional right of homestead property when non-attachable money judgment lien exists, you have to file a proper affidavit with the County Circuit Court to avoid the lien on sale or refi (the exercise of your Constitutionally-protected homestead rights). It has to be a correct in form affidavit, properly signed and notarized. This is the statutory process to avoid these non-attachable liens, which would attach at a sale if not avoided statutorily by the homesteader. There is a 45 day delay to allow the lienholder to contest your homestead claim. If they do, there will be a hearing and you'll need to testify that the real property has been your homestead since you acquired it. That should avoid their lien and you can then sell or refi.
21  Flordia Debtor / Post a Question / Re: NCO calling me at work - Need help on: August 07, 2008, 01:36:09 PM
Also, I forgot to ask a question. Are liens on your home allowed in the state of Florida? Can a credit card or collection firm place on lien on your home, the home you live in? Not that this applies to me, since I have no assets. I promised my friend (who's going through a similar situation) I would find out for him. I also suggested that he joins this web site, which specializes in Florida. Thank you.

Liens on Homestead Property are controlled by the FL Constitution. I think it's Article 10, section 4.
A money judgment from a credit card debt does not attach to homestead property.
However, if you sell or refi, you have to go through a homestead exemption affidavit process with a 45 day delay on sale or refi.
It's under 'Notice of Homestead prior to Levy' in section 222 of the Florida Statutes, I believe.
22  Flordia Debtor / Post a Question / Re: SOL Dates on: June 06, 2008, 07:21:45 AM
Quote from: "tdx27"
The SOL for an open account is 4 years here in Florida.

When do they start and end the SOL period. I believe they start when you 1st go 30 days late. Is that correct?

If a collector files suit against you for a debt, do they count the date they put the papers in at the court, the date you are served, the date of the hearing or some other date as the end point for the SOL period?

Thanks!


The Open Account cause of action is transaction based.
So, it's conceivable that the SoL date could be renewed after the point of the breach, which is the commencement of the delinquency, which is the first missed payment date, if the card holder was permitted by the creditor to conduct a transaction after the default and did conduct a purchase or cash advance transaction.
In most cases, it's the first missed payment date.

The tolling occurs the date the case is filed with the clerk of the court.

So, the SoL time is between first missed payment date and filing date of the complaint.
23  Flordia Debtor / Post a Question / Re: Which SOL? on: May 29, 2008, 01:47:56 PM
Quote from: "southgal6"
I have a question regarding the SOL with my private Access Loan. The contract reads that the laws of the state of Ohio will govern if there is any dispute. Ohio's SOL is, I believe, 10 years. I'm confused because I think that I read somewhere that FL law doesn't allow this. I'm hoping that I remember correctly.
After the conversation, I dug into my boxes of papers (not fun!!) that I have stored and found that the first payment was due on April 5, 2003. When told this, the reply was that even if the FL SOL goverened, they consider default to be three months after the first payment was due, which would mean that they have until June 5 of this year. My argument is that state law trumps their "opinion." Where do I stand with this?  :?

Thanks


The statute of limitations runs from the moment of the breach - the first missed payment date. not some time after.
They are wrong.
Look through the FL case law section of this site on the SoL related cases.
SoL is determined by the law of the forum state not the contract state because people don't make a contract with the anticipation of breaching it.

So, the choice of law in the contract applies to the express contractual terms of the agreement only.

So, the maximum SoL possible would be 5 years unless the contract state has a shorter SoL, which is borrowed by FL's borrowing statute, F.S. 95.10, in the FL limitations law, chapter 95, Florida Statutes.

But to get the 5 years, the plaintiff must introduce authenticated writings on the record of the court sufficient in law to constitute a 'written instrument', otherwise the 4 year SoL applies.

Start digging through the FL case law section here.
24  Flordia Debtor / Post a Question / Hudson & Keyes on: May 12, 2008, 07:17:15 PM
Quote from: "mads"
Thank you, Fraudfighter, for your response. It had been a few days since the 20 days I received a settlement letter for 70%. Last Wednesday, another letter came in advising me that I had one day after the receipt of this particular letter to call them and do a check by phone for 50% of the balance. This letter also indicated it was my "last chance" before they proceeded with "further action". So, the order is like this: first dunning letter giving me 30 days, 31 days after this a settlement letter for 70% of the balance giving me 20 days to send this money in, then 22 days later another letter asking me to do a check by phone for 50% of the balance. So, now, I guess their next step is to file lawsuit? I keep checking my county court web site every day to see if something in my name appears. Fortunately, nothing so far. Hopefully, it will stay that way.

I have confirmed beyond the shadow of any doubt that this collection firm has bought the debt from Bank of America. Bank of America no longer owns this account.

How do I file an extension of time should they sue?

Any other recommendations?

Thank you all for your help.


If they are demanding you pay and you don't have the money to pay, there is not alot you can do.
25  Flordia Debtor / Post a Question / Hudson & Keyes on: May 12, 2008, 07:13:09 PM
Quote from: "mads"
Thank you for the information you have given  me, and for your patience.

I have one question about this. When a JDB sues you in the state of Florida (which I've heard from several sources that it is completely biased in favor of JDBs), what does a judge normally consider proof? Is proof the originally signed application? Is proof a single or a combination of old credit card statements? Is proof a copy of the credit card agreement? Or is it a combination of all of these? I'm wondering what the best tactic is to respond to a lawsuit initiated by a JDB. I thank you all in advance for any help or any further information you can provide. Thanks, again.


Unless they produce original credit records that are authentic and probative as to your liability, then they are subject to Florida Evidence Code attacks by you.

If they just produce third party documents and third party affidavits, you attack them as in violation of the Florida Evidence Code, as non-authentic and failing to meet the Best Evidence Rule, and third party hearsay, failing to meet the Business Records exception to the hearsay rule.

Any third party affidavit is lacking in personal knowledge as to the facts and events at issue and is barred by the Summary Judgment rule. which I think is 1.510.

An anonyomous credit card holder agreement lack probativeness as to the liability of any party and is not a written instrument under FL law.
26  Flordia Debtor / Post a Question / Hudson & Keyes on: May 12, 2008, 07:03:00 PM
Quote from: "mads"
Thank you, Fraudfighter, for your response. It had been a few days since the 20 days I received a settlement letter for 70%. Last Wednesday, another letter came in advising me that I had one day after the receipt of this particular letter to call them and do a check by phone for 50% of the balance. This letter also indicated it was my "last chance" before they proceeded with "further action". So, the order is like this: first dunning letter giving me 30 days, 31 days after this a settlement letter for 70% of the balance giving me 20 days to send this money in, then 22 days later another letter asking me to do a check by phone for 50% of the balance. So, now, I guess their next step is to file lawsuit? I keep checking my county court web site every day to see if something in my name appears. Fortunately, nothing so far. Hopefully, it will stay that way.

I have confirmed beyond the shadow of any doubt that this collection firm has bought the debt from Bank of America. Bank of America no longer owns this account.

How do I file an extension of time should they sue?

Any other recommendations?

Thank you all for your help.


If you have to file a court paer, it needs to follow the basic rules for form.
It needs to have a header on page 1 of the motion, followed by the title of the motion: Defendant's Motion for Time Enlargement, Fla.R.Civ.P. 1.090b.
Then you need to make a series of statements separated in numbered paragraphs.

The header to the motion:
(centered:)
IN THE COUNTY COURT IN AND FOR Huh COUNTY, FLORIDA.

(left justified:)
NAME OF PLAINTIFF
           v.
NAME OF DEFENDANT

Case No. 0-xxxxxxxxxxx
---------------------------------------/
       
(then the motion title and motion body)
27  Flordia Debtor / Post a Question / Hudson & Keyes on: May 09, 2008, 08:07:18 PM
Quote from: "mads"
Thanks. I'm going to start reading that as soon as I get a chance. Do you mean if they file and I get served a summons, I have five days to answer the complaint? That's a terribly short time to develop an answer. I thought I had longer, like 30 days or so.

Also, what is the pre-trial conference? Is there always a pre-trial before a trial date is set? What goes on during this pre-trial? I've got to get myself familiar with the process.

I apologize for my lack of knowledge about this. I come from a completely unrelated field/background. I thank you all for all the kind help you have provided me.


If they sue on a $5200 debt, that takes it out of small claims, since small claims is $5K and below.

You have 20 days to file an answer to the complaint, but you can file a motion for time enlargement under Rule 1.090b and request more time.
Obviously, if you can't afford an attorney, you will need time to learn how to properly prepare and file an answer. That is just cause for time enlargement, because alot of legal research is involved for a pro se to prepare defenses, and since defenses not raised in the answer are generally considered waived.

You can also file preliminary defense motions under the enumerated types of defense motions under Rule 1.040.

Filing a prelim defense motion tolls the 20 day clock until the motion is dispositioned.
28  Flordia Debtor / Post a Question / FYI---This board on: February 28, 2008, 03:11:42 AM
I guess nobody in FL has debt problems or is getting sued on credit card debt, huh?
29  Flordia Debtor / Post a Question / Re: CACH LLC suit on: February 27, 2008, 04:50:13 AM
Quote from: "grossman"
Hopefully, somebody other than just me and Ruby are still monitoring these boards!!

Anyways, here goes….Going to court for the second time for CC debt. Received summons last week with a pre-trial scheduled in a couple of months. I knew this one was coming as I have gotten into the habit of monitoring the clerk of court site.

Being sued by Rubin and Debski out of Jacksonville and plaintiff is CACH LLC (as an assignee of Household Bank). They apparently bought this debt back in 2006. It is a defaulted CC for HSBC out of Nevada. I believe credit card was defaulted on in either 2003 or 2004, not sure which as I lost a large amount of records during hurricanes of 2004. I will have to check any older bank statements I still have left. First late payments were most likely mid 2004.

Here is the complaint:

CACH, LLC,
ASSIGNEE OF HOUSEHOLD BANK, a corporation, Plaintiff,
vs.
ME, Defendant.

COMPLAINT
The Plaintiff, CACH, LLC, sues the Defendant, ME, and alleges:

1. This is an action for damages that do not exceed $5,000.00, exclusive of interest, court costs and attorney's fees.

2.The original credit grantor established a credit card account, bearing the number xxxxxxxx, in the name of the Defendant and issued a credit card to the Defendant.

3.The credit card and the original credit card agreement (the "Agreement") were sent to the Defendant. Upon information and belief, Defendant is in possession of the original Agreement. A copy of the Agreement is attached and incorporated herein by reference.

4.Defendant, or other authorized by the Defendant, used the account to incur charges, thus accepting the terms ofthe Agreement and agreeing to be bound thereunder.

5. Defendant breached the Agreement by failing to make payment when due.

6. Plaintiff purchased and owns the Defendant's defaulted credit card account and succeeded to all the rights of the original credit grantor.

7.Defendant owes Plaintiff $XXX.XX plus interest on the credit card account.

8. All conditions precedent to bringing this action have occurred or have been waived.

9.Plaintiff is obligated to pay its attorneys a reasonable fee for their services. The Agreement provides for the
recovery of attorney's fees. In the event of a default, a reasonable attorney fee would be $400.00. WHEREFORE, Plaintiff demands judgment for damages, plus interest, costs and attorney's fees.



All that is attached to complaint is a card member agreement that that actually says GENERIC AG1138V across the top. No statements or agreement signature card. The agreement states that Neveada law is applicable and the SOL in Nevada is 6 years.

My initial thoughts:
I am not sure that this account is outside the Florida SOL of 4 years or 5 years, though I may argue if they cannot prove otherwise with statements.

I am contemplating an filing an MTD based upon failure to attach and failure to allege all the necessary elements of a valid cause of action. I know that it will probably fail due to the procedural vs. substantive view of rule 1.130(a), but I am going to be a pain in the ass as long as I can.

I will file my answers after and IF I file the MTD and use SOL and  Failure to state a cause as affirmative defenses along with any other ones I can incorporate….

I will then see what is offered at mediation during the pre-trial.

Not overly worried about a judgment as I am judgment proof and the amount is not large, just looking to give a fight and get into a better position.

Any  thoughts?

Thanks!!

Ruby, hopefully it is more than just you and me left. I think this board is extremely valuable and would like to offer any services I can provide to keep it going….


Unless the PLTF's Complaint court papers show that the SoL has expired, the court won't dismiss on SoL prior to your filing an answer and usually won't after you file an answer unless you have conclusive proof. You would have to move for summary judgment.

You raise SoL as an affirmative defense and the PLTF has to disprove it to obtain summary judgment. If the PLTF can't conclusively prove that the debt is not time-barred that is grounds for you to oppose summary judgment by the PLTF.

SoL timing depends on commencement of the delinquency, the 30 day late that became 60, 90, 120 etc.., not the last payment if the action is not founded on a written instrument, which may be the case for you.

You can file a lack of attachment MTD, but that will usually be converted for a motion for more definitive statement, where the PLTF will be granted usually 60 days to come up with the documents their claim is based on. In effect, you are forcing on the clock to provide prima facie proof.

Hopefully, they won't be able to get documents from the OC sufficient in law to constitute a written instrument under FL law so that the 4 year SoL will apply.

Just a Credit card Holder Agreement is not a written instrument.

The written instrument has to show acknowledgement by the party to be charged for the debt ON THE FACE OF THE WRITING and it must show a means to determine the amount of the debt ON THE FACE OF THE WRITING.

Multiple writings can be grouped together as one writing if they link together by referencing so it is clear they are contemporaneous to when the agreement was made.

That is what you have to attack them on- the writings from the OC, or lack thereof.

And if they throw third party affidavits (they are a third party, not the OC, and thus lack personal knowledge of the account) you throw the FL Evidence Code at them for Failure of the Business Records Exception to the Hearsay Rule of the FL Evidence Code.

Also, affidavits is support of summary judgment must be from personal knowledge which excludes third party JDB record custodian affidavits.

So, if they don't come up with the right documents as required by the rule of law. you argue that they lack prima facie proof and move for dismissal at trial.
30  Flordia Debtor / Post a Question / Re: legal reaging and FL SoL on: February 27, 2008, 04:27:42 AM
Quote from: "rubyruby27"
Fraud, this question is for you if you are still coming here.

  If an account is legally reaged  but its never brought current does the SoL changed.

Seeger v AFNI- is about a class action suit against AFNI for adding a collection fee to the amount owed.  The Judge ruled that a cell phone is a credit transaction and that the OC whomever it is can't charge a collection fee.  The state credit card protection acts does not allow for this fee either therefore they are in violation of the FCRA , FDCPA and WCA.

Does florida have a law that allow for collections fees to be attached to the account.  

This case was in Wisconsin and the Judge wrote a 44 page opinion its on IC.  AFNI has appealed this decision.

I am looking for specifically for anything I can use to make AFNI see my point, they should delete thier TL otherwise they will be risking another similiar suit in Florida.  

Can you guide me.


Does florida have a law that allow for collections fees to be attached to the account?  

Provisions for Collection fees have to be stipulated in the agreement between the parties with any ambiguity in the terms of the contract going against the party that wrote the contract, which would be the creditor.
 
If collection fees are not stipulated in writing, the debtor could object.

Why do you think FL would see a necessity for a statute beyond the common law?

The SoL is based on the commencement of the delinquency.
The delinquency would have to be cured for the running of the SoL to be affected, absent a new promise to pay or payment.
So, some credit reporting action would not affect the SoL if the delinquency is not affected.
I don't see how a delinquency can be legally reaged if it is not cured.

Wisconsin has a credit card protection act.
Florida does not, to my knowledge.

Can you post the text of this case and Wisconsin's credit card protection act here, please?
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