Maria Perez
Aug 3, 2009, 02:56 PM
Hello, I'm currently from Florida, mother of 4 children. And I have been served with a Chase credit card summons in which I had up to today to file a response in which I did. Through the process of Lack of Knowledge(that the company is established in DE), ( Admit (example: that I do reside in Florida) and Deny the rest of the statements in which they financial demages that exceed $17,000. Then stating affirmative defenses, such a:
Plaintiff complaint and each cause of action therein fall to state facts sufficient to constitue a cuase of action against the defendant, 2. Plaintiff's lack standing at all times herein releveant, Plaintiffs lack standing to proceeed in the subject action. 3. Plaintiff has failed to provide sufficient proof of for this alleged debt. 5. Failure of Condition Precedent. Plaintiff failed to perform a condition precedent to filing this instant action in that it failed to provide a fully itemized statement for the total balance amount you are asking in paragraph so and so in which defendant denies is correct, including the interest rate being charge, plus late fees and cost of the suit. 5. Plaintiff has filed to confirm if this rate falls within state usury limits.
I have ran out of money, because I've invested all my capital outside the country and due to the real estate turmoil it was stopped but now in a month or so it will start again due to some capital injection through a joint venture. But the truth is that maybe in a couple of months from now I'll have money but at the present time I don't have a dime. I want to know how can I buy time a couple of months to give time for a business that I'm doing falls through and the I can negotiate with this entity a lump sum payment? Is it true that I should also file a discovery request and how to do I write this?
Thank to all so much!
Plaintiff complaint and each cause of action therein fall to state facts sufficient to constitue a cuase of action against the defendant, 2. Plaintiff's lack standing at all times herein releveant, Plaintiffs lack standing to proceeed in the subject action. 3. Plaintiff has failed to provide sufficient proof of for this alleged debt. 5. Failure of Condition Precedent. Plaintiff failed to perform a condition precedent to filing this instant action in that it failed to provide a fully itemized statement for the total balance amount you are asking in paragraph so and so in which defendant denies is correct, including the interest rate being charge, plus late fees and cost of the suit. 5. Plaintiff has filed to confirm if this rate falls within state usury limits.
I have ran out of money, because I've invested all my capital outside the country and due to the real estate turmoil it was stopped but now in a month or so it will start again due to some capital injection through a joint venture. But the truth is that maybe in a couple of months from now I'll have money but at the present time I don't have a dime. I want to know how can I buy time a couple of months to give time for a business that I'm doing falls through and the I can negotiate with this entity a lump sum payment? Is it true that I should also file a discovery request and how to do I write this?
Thank to all so much!