HOUSEHOLD FINANCE INDUSTRIAL LOAN CO OF IOWA vs JAMES W PIERCE, 2010 CV 04457, No. 15367478 (Ohio State, Montgomery County, Court of Common Pleas Aug. 20, 2010) (2024)

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`1. VIOLATION OF JUDICIAL PROCESS BY THE PLAINTIFF —
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`IN VIEW OF THE FACT THAT DURING THE PLEADINGS STAGE OF A CIVIL LAWSUIT THE
`PLEADINGS ARE THE DOCUMENTS BY WHICH EACH PARTY, INCLUDING THE PLAINTIFF, SETS HIS
`OR HER INITIAL CASE BEFORE THE COURT, AND, MOREOVER, THAT ONCE A COMPLAINT HAS
`BEEN FILED AND A MOTION OF RESPONSE (ANSWER) HAS BEEN FILED (IN THIS CASE, SAID
`RESPONSE/ANSWER WAS FILED WITH AND ACCEPTED BY THE COURT ON THE 215T DAY OF
`JUNE, 2010,AND ATTACHED HERETO, INCLUDED TWENTY ONE PAGES OF MATERIAL FACTS AND
`INFORMATION), IT IS THE PLAINTIFF'S OBLIGATION AND RESPONSIBILITY TO THE COURT AND TO
`THE DEFENDANT TO REPLY TO THE MOTION OF RESPONSE (ANSWER) THAT ASSERTED MORE
`THAN EIGHT PAGES OF NEW AND INDISPUTABLE FACTS AND THIRTEEN PAGES OF
`ATTACHMENTS IN THE CASE. NOT ONLY HAS THE PLAINTIFF {HFC/BABco*ck 8: WASSERMAN)
`IGNORED THIS RESPONSIBILITY AND REQUIREMENT OF PROPER JUDICIAL PROCESS, BUT THEY
`HAVE IN FACT, WITHOUT PROPER COURT CERTIFICATION, PROCEEDED IMMEDIATELY, AS THEY
`HAVE DONE THROUGHOUT THIS PROCESS, PREMATURELY AND ILLEGALLY, ATTEMPTING TO
`MANIPULATE THIS COURT INTO A QUICKJUDGEMENT BASED ON FALSE AND MISLEADING
`STATEMENTS AND DOCUMENTATION TRYING TO USE ANY DESPICABLE MEANS POSSIBLE TO
`SECURE FUNDS TO WHICH THEY ARE NOT RIGHTLY ENTITLED. AT THE APPROPRIATE POINT IN
`THE JUDICIAL PROCESS, THE DISCOVERY OF DOCUMENTS AND INFORMATION BY THE
`COMPLAINANT AND, PARTICULARLY, THE DEFENDANT WILL BE INVALUABLE TO THIS COURT IN
`UNDERSTANDING THE REAL TRUTH OF THESE MATTERS (INCLUDING FOR EXAMPLE THE TAPES
`OF THE CONVERSATIONS BETWEEN THE DEFENDANT AND THE PLAINTIFF] BABco*ck 8L
`WASSERMAN) ARE VITAL TO THE RIGHTS OF THE DEFENDANT TO A FAIR AND IMPARTIAL TRIAL,
`AS THE ONLY WAY TO ENSURE THAT THE TRUE AND HONEST FACTS OF THIS CASE ARE BROUGHT
`TO LIGHT AND HEARD BY AJUDGE WHO WILL ACTUALLY LISTEN TO AND CONSIDER THEM,
`UNLIKE THE COMPLAINANT AND B&W WHO HAVE REFUSED TO LISTEN 0R CONSIDER ANYTHING
`THAT GETS IN THE WAY OF THEIR BLIND PURSUIT OF FUNDS THAT THEY ARE NOT ENTITLED TO.
`MOREOVER, AS ACTED UPON BY BOTH THE US. CONGRESS AND NUMEROUS COURTS, THE
`RULES GOVERNING TRIALS ARE DESIGNED AND INTENDED TO ENSURE THAT INTERROGATORIES
`REQUIRE BOTH PARTIES (NOT JUST THE DEFENDANT) TO CONFER AND DEVELOP A DISCOVERY
`PLAN AND MEANINGFULLY DISCUSS SETTLEMENT POSSIBILITIES. WHILE THE PLAINTIFF HAS
`NOT FOLLOWED THROUGH ON ANY OF THESE JUDICIAL PROCESS REQUIREMENTS AND
`CONTINUALLY AND ILLEGALLY WITHELD THE REQESTED VERFICATION AND VALIDATION
`DOCUMENTATION TO WHICH THE DEFENDANT IS DULY ENTITLED UNDER THE US. FAIR DEBT
`COLLECTION PRACTICES ACT (FDCPA), AS FURTHER DETAILED IN NO. 2 BELOW, THEY
`NEVERTHELESS, BELIEVE THAT THEY, AS A ROGUE, EXTERNAL ASSIGNMENT DEBT COLLECTOR,
`ARE ABOVE AND BEYOND THE REQUIREMENTS OF JUDICIAL PROCESS AND FEDERAL LAW
`ALLOWING THEM TO PERSIST IN THEIR PRACTICES OF INTIMIDATION AND HARRASSMENT AND
`KNOWINGLY WITHHOLDING THE REQUESTED INFORMATION, THEY HAVE OR SHOULD HAVE,
`ABOUT THE DEBT IN QUESTION IN THIS CASE, COLLECTIONS EFFORTS ARE TO CEASE UNTIL THIS
`INFORMATION HAS BEEN PROVIDED. CONSEQUENTLY, THE DEFENDANT, BY VIRTUE OF THIS
`FACT THAT THEY HAVE REFUSED TO PROVIDE THE DEFENDANT WITH SAID INFORMATION IN
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`THE REQUIRED TIMELINE THAT THEY THEMSELVES SET FORTH AND THEN IGNORED (SEE CLIFF
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`BABco*ck’S LETTER OF MAY 27, 2010, MY RESPONSE OF JUNE 18, 2010 AND THE ORIGINAL
`LAWSUIT/COMPLAINT'FILED BY CLIFF BABco*ck ON .IUNE 1, 2010), THAT WAS REQUESTED
`MONTHS AGO IN A DESIRE AND AN EFFORT BY THE DEFENDANT TO REASONABLY RESOVE THIS
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`MATTER, CONSTITUTE , IN AND OF ITSELF, A BREACH OF LAW BY THE PLAINTIFF THAT
`RENDERED THE DEBT IN QUESTION NULL AND VOID AT THE EXPIRATION OF THE RESPONSE
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`PERIOD ESTABLISHED BY FEDERAL LAW FOR THE PLAINTIFF TO PROVIDE THE DEFENDANT WITH
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`WHAT HAD BEEN RIGHTFULLY REQUESTED TO CLARIFY AND CONFIRM, IF POSSIBLE, THE
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`ASSERTIONS OF THE PLAINTIFF (HFC/BABco*ck 8L WASSERMAN). MONTGOMERY COUNTY
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`COURT WAS PROVIDED COPIES OF ALL OF THE DEFENDANT’S LETTERS AND COMMUNICATIONS
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`IN THE DEFENDANT’S RESPONSE/ANSWER TO THE COMPLAINT, WHICH WERE PROPERLY
`STAMPED AND CERTIFIED BY THE COURT, A COPY OF WHICH IS ATTACHED HERETO.
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`VIOLATIONS OF THE U.S. FAIR DEBT COLLECTION PRACTICES ACT AND THE U.S. FAIR CREDIT
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`REPORTING ACT BY THE PLAINTIFF ( WHICH I WILL BE PURSUING WITH THE U.S. FEDERAL TRADE
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`COMMISSION AND THE NEW U.S. BUREAU OF CONSUMER PROTECTION AS SOON AS THIS
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`MATTER IS DISMISSED)-
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`WHETHER KNOWINGLY OR UNKNOWINGLY, THE PLAINTIFF (AN D, MORE SPECIFICALLY, THEIR
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`SUPPOSED REPRESENTATIVE, BABco*ck & WASSERMAN, WHO UNDER OATH WILL I AM SURE
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`CONFIRM THEIR TRUE STATUS IN THIS MATTER AS THE EXCLUSIVE PARTY SEEKING WHATEVER
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`FUNDS THEY CAN RECOVER THROUGH WHATEVER MEANS POSSIBLE) REPEATEDLY COMMITTED
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`MAJOR VIOLATIONS OF THE U.S. FAIR DEBT COLLECTIONS PROTECTION ACT AND THE U.S. FAIR
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`CREDIT REPORTING ACT, WHICH IS DESIGNED TO SHIELD AND PROTECT DEBTORS FROM UNFAIR
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`DEBT COLLECTION TACTICS BY DEBT COLLECTION ATTORNEYS, LIKE B&W, WHO ROUTINELY
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`OPERATE AS DEBT COLLECTORS, AND WITH MALICE OF FORETHOUGHT HEAPED SIGNIFICANT
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`FINANCIAL AND EMOTIONAL BURDEN AND STRESS ON THE DEFENDANT AT ATIME WHEN THE
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`DEFENDANT WAS ALREADY UNDER EXCESSIVE HURT AND PAIN, BOTH EMOTIONALLY AND
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`FINANCIALLY, AS HE HAD DOCUMENTED IN WRITING AND SHARED WITH THE PLAINTIFF.
`ALTHOUGH COMPLETELY DISREGARDED BY HFC AND BABco*ck 8: WASSERMAN THROUGHOUT
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`THIS PROCESS AS EVIDENCED BY THE TWENTY ONE PAGES OF ATTACHED DOCUMENTS AND
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`FACTS, THE ENTIRE PURPOSE OF THE U.S. CONGRESS ADOPTING THE U.S. FAIR DEBT
`COLLECTIONS PROTECTION ACT IS TO PREVENT THE PRECISE ABUSE AND DEGRADATION OF
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`PROCESS THAT HAS OCCURRED IN THIS CASE AND TO ENSURE THAT DEFENDANTS, SUCH AS MR.
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`PIERCE, ARE AFFORDED ALL OF THEIR DUE PROCESS CONSIDERATION AND ALL OF THE RIGHTS
`TO WHICH THEY ARE GUARANTEED BY THE GOVERNMENT OF THE UNITED STATES OF AMERICA
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`TO ENSURE THAT THE PROCESS IS FAIR AND EQUITABLE TO ALL PARTIES AND NOTIUST THE
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`DEBT COLLECTOR WHO BLINDLY PURSUE THEIR ONE GOAL AND OBIECTIVE WITHOUT ANY
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`RESPECT OR REGARD FOR THE APPLICABLE LAWS THAT ARE INTENDED AND DESIGNED TO
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`GUIDE AND PROTECT DEBTORS, PARTICULARLY DEBTORS SUCH AS MR. PIERCE WHO FIND
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`THEMSELVES IN AN UNTENABLE SITUATION THROUGH NO FAULT OF THEIR OWN THAT HAS
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`COMPLETELY CHANGED THEIR CIRMc*msTANCES FROM THE FIRST RELATIONSHIP WITH THE
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`PLAINTIFF THAT WAS ENTIRELY SATISFACTORY TO THE PLAINTIFF. FROM MY VERY FIRST
`LETTER, DATED OCTOBER 1, 2009, AS WELL AS, MY LETTER OF NOVEMBER 15, 2009, AND 50 ON
`AND SO ON, TOGETHER WITH TOO MANY VERBAL REQUESTS TO EVEN TRACK, ALL OF THE
`REQUESTS FOR VERIFYING AND VALIDATING INFORMATION, DOCUMENTATION, ASSISTANCE
`AND ACKNOWLEDGEMENT OF MY CHANGED CIRc*msTANCES WENT COMPLETELY UN HEADED
`AND IGNORED BY THE PLAINTIFF. BY VIRTUE OF THE FACT THAT MY REQUESTS FOR
`VERIFICATION AND VALIDATION OF THIS DISPUTED JUNK DEBT AND ALL OF MY OTHER
`REQUESTS, WHICH I ALWAYS MADE WITHIN THE 30 DAY TIME FRAMES THAT WERE IMPOSED
`ON ME BY THE PLAINTIFF, WERE NOT RESPONDED TO IN WRITING TO ME PRIOR TO THE
`PLAINTIFF ILLEGALLY ”JUMPING TO THE GUN” OF FILING AN UNNECESSARY AND
`UNWARRANTED FORMAL COMPLAINT WITH MONTGOMERY COUNTY CLERK OF COURTS, THE
`DEBT IN QUESTION AT THE TIME OF THIS FAILURE ON THE PART OF THE COMPLAINANT WAS
`DETERMINED TO BE AND EFFECTIVELY DECLARED NULL AND VOID.
`I AM STILL YET TO RECEIVE
`A VALID, WRITTEN ANSWER AND UNALTERED AND UNREDACTED DOCUMENTATION WITH
`CONSISTENT DATES AND AMOUNTS (FOR EXAMPLE, IN AN HFC LETTER OF MARCH 31, 2010 IT
`WAS 11,059.90, WHILE IN CLIFF BABco*ck’S LETTER OF MAY 27, 2010 IT WAS SUPPOSEDLY
`$15,926.50, AND THEN IN CLIFF BABco*ck'S LAWSUIT OF JUNE 1, 2010 IT WAS ANOTHER NEW
`FIGURE OF $15,799.85, AND THEN, ONCE MORE, IN A LETTER DATED JUNE 25,NEARLY ONE
`MONTH AFTER B&W FILED THEIR LAWSUIT, THE NEW NUMBER PULLED FROM SOMEWHERE
`WAS $16,445.17, AND THEN FINALLY, IN THE MOST RECENT MOTION FROM B&W —- EVANA
`DELON, THE NUMBER IS NOW SOMEHOW $15,799.85 AGAIN —ALL FOR A LINE OF CREDIT THAT
`WAS SUPPOSEDLY SIGNED BY ME WITH A TOTAL CREDIT LIMIT OF &10,000) , TO MY REQUESTS
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`TO WHICH I AM FULLY ENTITLED BY LAW AND THE GOVERNING PROVISIONS OF THE U.S. FAIR
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`DEBT COLLECTIONS PROTECTION ACT. TO HAVE THE AFFIDAVIT HFCALLEGEDLY SUPPLIED BE
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`INCONSISTENT WITH AT LEAST THREE OTHER WRITTEN CORRESPONDENCE THAT THE PLAINTIFF
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`SENT TO THE DEFENDANT EXACERBATES ALL OF THE SUSPICION AND CREDIBILITY ISSUES FOR
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`EVERYTHING HFC/B&W HAVE DONE THROUGHOUT THIS ENTIRE PROCESS, WHEREIN I HAVE
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`RESPONDED CONSISTENTLY AND WITHIN TIME CONSTRAINTS TO EVERYTHING THAT WAS SENT
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`TO ME BY HFC AND/OR B&W AND THEY HAVE BLATANTLY IGNORED AND DISREGARDED
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`EVERYTHING THAT WAS ASKED AND REQUIRED OF THEM. ADDITIONALLY, OTHER VIOLATIONS
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`BY LAW, WHICH, AGAIN, IN AND OF THEMSELVES, CONSTITUTE THE IMMEDIATE DISMISSAL OF
`THEIR COMPLAINT, INCLUDE BUT ARE NOT LIMITED TO, CONTACT WITH THIRD PARTIES IN AN
`ATTEMPT TO HARM THE DEFENDANT'S REPUTATION, REPEATED PHONE CALLS WITH THE
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`INTENT TO HARASS AND INTIMIDATE, AND CONTACTING THE DEFENDANT IN AN UNFAIR,
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`ABUSIVE OR DECEPTIVE MANNER. AS I AM ENTITLED, BY THE FEDERAL TRADE COMMISSION AS
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`THE ADMINISTERING AGENCY OF THE FDCPA, AS A WRONGED DEBTOR, FOR ALL OF THE
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`DAMAGE THEY HAVE INFLICTED FOR ASSOCIATED EM BARRASSMENT AND SUFFERING,STRESS
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`AND UNWILLINGNESS TO WORK WITH ME BY ACCELERATING THE TERMS AND AMOUNT,
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`PAINTING ME AS A DEADBEAT AND ADDING PAIN TO OUR ALREADY DEPLORABLE STATE,
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`I WILL
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`BE FORCED AND COMPELLED TO FILE A CIVIL ACTION SUIT TO RECOVER ALL OF SAID DAMAGES
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`INCLUDING ALL OF THE EXTRA COSTS THIS UNNECESSARY AND UNWARRANTED PROCESS IS
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`IMPOSING ON OUR NEGATIVE FAMILY BUDGET(LAW, BUSINESS AND SOCIETY, TONY MCADAMS,
`NANCY AND KRISTOFER NESLUND, 8TH EDITION, MCGRAW—HILL COMPANIES, INC.).
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`3.
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`A CLAIM ON WHICH RELIEF CAN BE GRANTED HAS NOT BEEN STATED BY THE PLAINTIFF -
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`SETTING ASIDE THE INACCURACY OF THE PLAINTIFF’S COMPLAINT, A CLAIM ON WHICH RELIEF
`CAN BE GRANTED BY THE DISTRICT COURT OF MONTGOMERY COUNTY HAS NOT, IN FACT, BEEN
`STATED BY THE PLAINTIFF FOR TWO PRIMARY REASONS: FIRST, THE ONLY PARTY TO WHICH THE
`DEFENDANT HAS ANY RELATIONSHIP WHATSOEVER, HFC, HAS ALREADY VOLUNTARILY AND
`SUM MARILY DISPOSED OF THIS MATTER BY UNILATERALLY CLOSING THE ACCOUNT, CLEARING
`THE BOOKS OF THE DEBT IN QUESTION AND REFUSING TO ACCEPT ANY MORE MONEY FROM
`THE DEFENDANT AND EVEN REFUSING TO TALK OR COMMUNICATE WITH THE DEFENDANT IN
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`ANY WAY, SHAPE OR FORM, WHICH IN ITS’ TOTALITY BASED ON THEIR ACTIONS AND
`STATEMENTS, CLEARLY SHOWS THAT HFC HAS ”WASHED THEIR HANDS” OF ME COMPLETE LY;
`AND SECOND, PARTY A (HFC) VOLUNTARILY SOLICITED AND EXTENDED AN UNSECURED LINE OF
`CREDIT IN AN AMOUNT WHICH THE PLAINTIFF REFUSES TO ACKNOWLEDGE, BUT WHICH IS
`UNDISPUTABLY FAR LESS THAN THE AMOUNT NOW IN QUESTION, TO PARTY 8 (MR. PIERCE)
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`AND AFTER RECEIVING ON TIME AND IN FULL REPAYMENT OF ALL MONIES OWING, AND AFTER
`THE FIRST BELOW MINIMUM PAYMENT CLOSED THE ACCOUNT PROVIDING NO RECOURSE OF
`ANY KIND TO THE DEFENDANT , AND ASSIGNED, SOLD AND OR IN SOME OTHER MANNER,
`AGAIN, WHICH PARTY A REFUSES T0 DISCLOSE, EXPLAIN OR ACKNOWLEDGE IN ANY WAY, THE
`DISPUTED DEBT IN QUESTION TO PARTY C (BABco*ck 8: WASSERMAN—WITH MULTIPLE
`REPRESENTATIVES NUMBERING AT LEAST FOUR TO DATE), WHICH PARTY B (MR. PIERCE) HAS
`NEVER ASKED FOR ANY MONEY, RECEIVED ANY MONEY OR OWES ANY MONEY. PARTY A (HFC)
`HAS ONE OF THE LARGEST LEGAL DEPARTMENTS IN THE COUNTRY AND IF IN FACT THEY TRULY
`BELIEVED THEY HAD A VALID CLAIM TO THE DISPUTED DEBT IN QUESTION AND WISHED TO
`RECOVER ANY MONIES, BEYOND THE THOUSANDS OF DOLLARS THAT HAVE ALREADY BEEN PAID
`TO THEM OVER THE YEARS, WOULD HAVE CHOSEN TO WORK WITH PARTY 8 (MR. PIERCE) TO
`RESOLVE THIS MATTER DIRECTLY (RESPONDING IN SOME MEANINGFUL WAY TO ONE OF THE
`MULTIPLE CERTIFIED LETTERS THAT MR. PIERCE SENT TO THEM IN AN EFFORT TO REASONABLY
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`AND PRO-ACTIVELY ADDRESS THE RADICALLY CHANGED FACTS AND CIRc*msTANCES OF MR.
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`PIERCE’S FINANCIAL PREDICAMENT AND LIMITATIONS) RATHER THAN UNILATERALLY
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`TERMINATING THE RELATIONSHIP WITH PARTY B (MR. PIERCE), CLOSING THE ACCOUNT,
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`WRITING OFF AND REMOVING THE DEBT COMPLETELY FROM THEIR BOOKS AND REFUSING TO
`TALK WITH, RECEIVE FURTHER PAYMENTS FROM OR COMMUNICATE IN ANY FURTHER WAY
`WITH PARTY B (MR. PIERCE). TOGETHER, THESE TWO INDISPUTABLE FACTS ALONE WARRANT
`THE IMMEDIATE DISMISSAL OF THIS COMPLAINT FILED BY PARTY C (B&W). MOREOVER,
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`PURSUANT TO THE COUNSEL OF FORT WORTH ATTORNEY AND CREDIT SPECIALIST JERRY
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`JARZOMBREK, WITH CONFIRMATION AND ACKNOWLEDGEMENT OF THE DATA PROBLEMS
`INHERENT IN THESE DEBT HAN DOFFS/SELLOFFS BY ROZANNE ANDERSON, GENERAL COUNSEL
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`FOR THE ASSOCIATION OF CREDIT AND COLLECTION PROFESSIONALS (ACA) INTERNATIONAL, I
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`DENY THE PLAINTIFF’S CLAIM AND DEMAND THEY SHOW ME AND THE COURT A VALID ,
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`UNALTERED CONTRACT WITH CONSISTENT DATES AND AMOUNTS ON EACH PAGE WITH A
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`SUPPOSED WITNESS I HAVE ACTUALLY HEARD OF, AND WHICH HAS MY PROPER SIGNATURE TO
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`DEMONSTRATE THAT THEY HAVE THE AUTHORITY TO SUE; AND HAVING FAILED TO DO SO
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`WITHIN THE REQUIRED THIRTY (30) DAY PERIOD FROM THE TIME OF THE REQUEST AND EVEN
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`HAVING FAILED TO DO SO SUBSEQUENT TO THIS EXPIRATION PERIOD, THE CLAIM IS DEEMED
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`NULL AND VOID AND THE CASE SHOULD BE DISMISSED WITHOUT FURTHER DELAY.
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`IT IS
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`ABUNDANTLY CLEAR THAT THE DEBT COLLECTOR (3&W) DOES NOT HAVE KNOWLEDGE OF OR
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`ACCESS TO THE REQUISITE FACTS AND DETAILS OF THIS DISPUTED DEBT, BEYOND THEIR
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`MISREPRESENTATIONS AND FALSIFICATIONS TO PROVE THEIR CASE, AND ARE, THEREFORE,
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`WASTING THE COURT’S LIMITED TIME AND RESOURCES.
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`IN SUMMARY AND CONCLUSION, FOR ALL OF THE FACTS AND REASONS CAREFULLY AND DUTIFLY
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`ENUMERATED ABOVE, ,THE COURT IS ASKED AND SHOULD IMMEDIATELY AND PROM PTLY GRANT THIS
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`MOTION TO DISMISS. AS SUPPORTED BY THE LAW AND JUDICIAL PROCESS, THE HONORABLE COMMON
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`PLEAS COURT OF MONTGOMERY COUNTY IS IMPLORED TO DISMISS THIS CASE WITHOUT FURTHER
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`DELAY OR DELIBERATION AS THE PLAINTIFFS ARE CLEARLY AND DELIBERATELY TRYING TO FURTHER
`HARM US IN AN ATTEMPT TO INTIMIDATE US AND TO AGGRESSIVELY ADD TO OUR ALREADY
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`SUFFOCATING BURDEN OF DEBT KNOWING THAT WE CANNOT AFFORD LEGAL REPRESENTATION AND
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`THAT ALL OF THE COPIES, NOTARIES, CERTIFIED MAIL AND 50 ON THAT IS ASSOCIATED WITH THIS
`ENTIRELY UNNECESSARY AND UNWARRANTED PROCESS ARE SIMPLY OVERWHELMING ALL OF THE
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`DEFENDANT’S RIGHTS AND DUE PROCESS THAT THE PLAINTIFFS HAVE IGNORED THROUGHOUT THIS
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`ENTIRE SAD AND DESPICABLE PROCESS; AND WE THEREFORE SEEK, ALONG WITH THE COURTS
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`DISMISSAL OF THIS CASE , THE IMPOSITION OF ALL COSTS ASSOCIATED WITH THE DEFENSE OF THIS
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`ACTION ON THE PLAINTIFF (HFC/B&W). THE ILLEGAL AND IMMORAL ACTIONS OF B&W TO TRY AND
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`MANIPULATE THE COURT SYSTEM INTO A QUICK AND UNWARRANTED JUDGEMENT, AS THE STANDARD
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`PRACTICE UPON WHICH THEY HAVE APPARENTLY BUILT THEIR WELL DESERVED REPUTATION OF
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`STOPPING AT NOTHING TO TRY AND COLLECT WHAT THEY ARE NOT ENTITLED TO FROM UNKNOWING
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`DEFENDANTS WHO CANNOT AFFORD TO DEFEND THEMSELVES IS DESPICABLE AND SHOULD NOT BE
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`CONDONED OR REWARDED BY THIS COURT. AS OTHERS HAVE TESTIFIED AGAINST 8&W, ”THEY DON’T
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`CARE ABOUT YOUR RIGHTS, THEY ONLY WANT YOUR MONEY" (EVEN IF THEY HAVE NO LEGITIMATE
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`CLAIM TO IT WHATSOEVER).
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`IN CONCLUSION, I IMPLORE THE COURT TO TAKE ALL OF THE ABOVE INTO FULL ACCOUNT. OWING .TO
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`UNTOWARD CIRc*msTANCES WHICH HAVE ARISEN IN OUR LIVES DURING THIS ECONOMIC RECESSION,
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`WE ARE IN DIRE WANT AND UNABLE TO MEET OUR DAILY NEEDS. WE HAVE BEEN UNABLE THUS FAR TO
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`GET ANYONE TO LISTEN TO AND HELP US IN OUR PRESENT DIFFICULTIES. NO BAILOUT IS AFFORDED TO
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`US AS IT WAS TO THE LARGE FINANCIAL INSTITUTIONS OF THIS COUNTRY. WE ARE NOT DEADBEATS AS
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`THE PLAINTIFFS HAVE PAINTED US TO BE. WE HAVE ALWAYS BEEN HARD WORKERS AND WERE
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`THROWN INTO A SITUATION THROUGH NO FAULT OF OUR OWN THAT HAS TURNED INTO OUR WORST
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`NIGHTMARE.
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`I THANK THE COURT FOR THEIR TIME, CONSIDERATION AND SWIFT ACTION iN BRINGING
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`THIS EMOTIONALLY AND TAXING MATTER T0 AJUST AND FAIR ENDING WITH THE GRANTING OF THIS
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`MOTION TO DISMISS.
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`T
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`MES W. PIERCE
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`SIGNED, DATED AND FILED THIS 20TH DAY OF AUGUST 2010
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`A COPY OF THE FOREGOING NOTICE WAS SENT VIA ORDINARY U.S. MAIL THIS 20TH DAY OF AUGUST,
`2010 TO BABco*ck 84 WASSERMAN {CLIFF BABco*ck, RAYJENNA, EVAN NA DELON 0R WHOEVER MAY BE
`HANDLING THE CORRESPONDENCE ON THIS UNJUSTIFIED COMPLAINT THIS WEEK).
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`fiworn to and signed :‘n mq WC):
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`*: In and for the State of Ohio
`5 my Commission Expires MI. 3. 2014
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`n O t‘w pu 1:” {CI
`8 — 2, o , l' o
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`EN THE MONTGOMERY COUNTY COMMON PLEAs COUR'E III AREA tit*
`MONTGOMERY COUNTY, OHIO
`JUH 2,
`PM I; IA
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`HOUSEHOLD FINANCE
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`*
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`OE VIRGINIA OR IOWA?
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`* RESPONSE [ANSWER TO COMPLAINT
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`C/O CLIFF BABco*ck OF
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`* CASE NO: 2010CVE00536
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`CLEVELAND, OHIO
`
`VS
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`*
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`*
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`'
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`JAMES w. PIERCE OF
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`* COMPLAINT RECEIVED BY MAIL ON JUNE 2, 2010 AND
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`OHIO (NOT IOWA)
`15
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`* RESPONDED TO THIS 21ST DAY OE JUNE 2010
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`THE PLAINTIFF AND, MORE PARTICULARLY, THE ATTORNEY FOR THE PLAINTIFF IN THIS COMPLAINT HAS
`MATERIALLY MISREPRESENTED AND INTENTIONALLY OMITTED THE KEY FACTS IN THIS MATTER AND
`KNOWINGLY, WILLFULLY, AGGREGIOUSLY AND UN LAWFULLY VIOLATED THE REQUIREMENTS OF THE
`US. FAIR DEBT COLLECTIONS PROTECTION ACT , THE U.S. FAIR CREDIT REPORTING ACT AND THE RULES
`AND REGULATIONS PROMULGATED BY THE FEDERAL TRADE COMMISSION, ALL OF WHICH ARE
`DESIGNED TO ENSURE THAT THE RIGHTS AND DUE PROCESS GUARNATEED DEBTORS ARE NOT
`COMPLETELY IGNORED AND TRAMPLED ON (AS THEY HAVE BEEN IN THIS CASE) TO SUCH AN EXTENT
`THAT THIS COMPLAINT MUST BE DECLARED NULL AND VOID AND IMMEDIATELY DISMISSED BY THE
`COURT. THE FACTS IN THIS MATTER ARE CLEARLY DELINEATED AS FOLLOWS AND IN THE
`ATTACHMENTS FOR THE REVIEW AND ACTION OF THE COURT T0 DISMISS THIS COMPLAINT AND UNDER
`THE LAW OF NULLIFICATION RENDER THIS MATTER TO HAVE NO LEGALVALIDITY AND TO EFFECTIVELY
`ANNUL AND INVALIDATE THIS COMPLAINT BASED ON THE WEIGHT OF THE OVERWHELMING EVIDENCE
`PRESENTED BELOW AND IN THE DEMAND FOR FAIRNESS AND JUSTICE THE DEFENDANT REJECTS, DENIES
`AND DISPUTES EVERYTHING THAT HAS BEEN PRESENTED TO THE COURT BY CLIFF BABco*ck, WHICH IS
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`MORE SPECIFICALLY REPUDIATED AS FOLLOWS.
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`1. THE MOST BLANTANT AND REPUGNANT OF THE MULITIPLE AND CONTINUING UNLAWFUL
`VIOLATIONS OF THE US FAIR DEBT COLLECTIONS PROTECTION ACT (FDCPA), COMMITTED
`MOST RECENTLY BY MR. BABco*ck, WAS HIS THREATENING PHONE CALL ON MAY 27, 2010 AT
`11:48 A.M. (FROM THE PHONE NUMBER 216-369—2882) IN WHICH HE NOT ONLY REFUSED TO
`LISTEN TO ANYTHING I HAD TO SAY, BUT INTERRUPTED ME WHEN I WAS TRYING TO SAY IT AND
`VERY THREATENINGLY EXPRESSED THAT IF I WAS NOT GOING TO PAY IN FULL IMMEDIATELY
`THAT ”HE WOULD JUST HAVE TO DO WHATEVER HE HAD TO DO TO ME” IN THE MOST VICIOUS
`AND MEAN SPIRITED TONE I HAVE EVER BEEN SUBJECT TO, PARTICULARLY BY SOMEONE WHOI
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`HAD NEVER SPOKEN TO BEFORE AND CERTAINLY DID NOT KNOW FOR CERTAIN WHO HE EVEN
`WAS. OBVIOUSLY, IN VIEW OF HOW UPSET HE WAS HE THEN IMMEDIATELY PREPARES AND
`MAILS ME A LETTER ON THE VERY SAME DAY, MAY 27, 2010, DEMANDING THAT I FOLLOW—UP
`WITH ANOTHER INDIVIDUAL, A RAYJENA,THAT I HAD NEVER DEALT WITH BEFORE AND HAD
`NO KNOWLEDGE OF WHATSOEVER (WITH NO EXPLANATION IN THE COMMUNICATION AS TO
`WHO HE WAS OR WHO HE REPRESENTED) AND THAT I MUST DO THIS WITHIN THIRTY (30) DAYS
`OF THE DATE OF THIS LETTER OF MAY 27, 2010. ALL OF THIS OCCURRED OVER THE MEMORIAL
`DAY WEEKEND DELIBRATELY MAKING THE DEFENDANT LOSE FOUR DAYS OF RESPONSE TIME.
`AS I HAVE IN EVERY OTHER INSTANCE THROUGHOUT THIS ENTIRE PROCESS, | RESPONDED WELL
`WITHIN THE THIRTY (30) DAY PERIOD ON JUNE 18, 2010 BY SENDING MR. BABco*ck AND MR.
`JENAA REGISTERED/CERTIFIED LETTER RESPECTFULLY REQUESTING ALL OF THE VALIDATION
`DOCUMENTATION TO WHICH I AM ENTITLED UNDER FDCPA. YET, LONG BEFORE EVEN WAITING
`TO RECEIVE MY LETTER OF RESPONSE, WHICH I AM AFFORDED BY THE FDCPA, MR. BABco*ck
`ILLEGALLY ON JUNE 1, 2010(THE TUESDAY AFTER MEMORIAL DAY) FILES A LAWSUIT AGAINST
`ME FOR ALL OF THE VERY SAME THINGS THAT HAVE BEEN IN ERROR AND DISPUTE FROM THE
`DAY I WAS FIRST UNEMPLOYED AND WHICH HE WOULD HAVE BEEN FULLY AWARE OF IF HE
`TRULY REPRESENTED HFC AND HAD THEIR ENTIRE FILE ON'THIS MATTER. (ALSO, IT MUST, IN ALL
`FAIRNESS, BE POINTED OUT, THAT THIS PATTERN OF QUESTIONABLE BEHAVIOR AND RULE
`BREAKING ACTIVITIES MAY WELL BE STANDARD PRACTICE BASED ON THE COMMENTS AND
`CRITIQUES OF BABco*ck AND WASSERMAN ON THE INTERNET WHERE THEY ARE SAID BY
`OTHERS WHO HAVE HAD TO DEAL WITH THEM AND HAVE EVALUATED THEM, IN THEIR
`OPINION, AS BEING ONE OF THE MOST AGGRESSIVE, HARASSING AND LOWEST RATED JUNK
`DEBT BUYERS/COLLECTORS IN THIS DUBIOUS AND HIGHLY SUSPECT INDUSTRY OF JUNK DEBT
`COLLECTORS —— RECEIVING ONE STAR FOR THEIR QUALITY AND PROFESSIONALISM ON A SCALE
`OF FIVE STARS.)
`IN FACT, IT WAS SAID IN THE ONE REVIEW THAT "THEY (BABco*ck) DON'T CARE
`ABOUT YOUR RIGHTS, THEY ONLY WANT YOUR MONEY.” IN KEEPING WITH THIS PATTERN AND
`TRACK RECORD OF COMMENTS AND EVALUATIONS BY OTHERS WHO HAVE BEEN FORCED TO
`DEAL WITH BABco*ck, HE HAS STILL NOT RESPONDED IN ANY WAY, SHAPE OR FORM TO MY
`LETTER OF JUNE 18, 2010, CHOOSING INSTEAD TO ABUSE NOT ONLY THE DEFENDANT, BUT
`ALSO THE COURT, IN PREMATURELY TRYING TO USE THE COURT TO UNJUSTIFIABLY OBTAIN A
`QUICK AND UNWARRANTED JUDGEMENT AGAINST A DEFENSELESS AND UN KNOWLEDGABLE
`DEBTOR FOR A DISPUTED AND SERIOUSLY INFLATED DEBT TO WHICH HE IS NOT LAWFULLY
`ENTITLED. THISCOMPLETE AND UTTER DISREGARD AND DISDAIN FOR NOT ONLY THE RIG HTS
`AND DUE PROCESS THAT IS GUARANTEED TO THE DEFENDANT, BUT ALSO, EVEN MORE
`IMPORTANTLY, THE LAWS OF THE UNITED STATES OF THE AM ERCIA AND PROPER JUDICIAL
`PROCESS FOR USING THE COURTS OF THIS COUNTRY IN THE MANNER AND IN ACCORDANCE
`WITH SAID LAWS OF CONGRESS AND THE U.S. FEDERAL TRADE COMMISSION, WHICH IN ALL OF
`ITS TOTALITY DEMANDS AND REQUIRES THAT THIS MATTER BE IMMEDIATELY DECLARED NULL
`AND VOID AND DISMISSED ON THE MISCONDUCT OUTLINED ABOVE, AS WELL AS BELOW IN ALL
`OF THE OTHER SIMILAR INSTANCES OF ILLEGAL VIOLATIONS OF THE FDCPA COMMITTED
`DIRECTLY BY THE PLAINTIFF, INCLUDING, AMONG OTHERS, EXHIBIT 2 (C) BELOW INVOLVING
`
`MS. MARGARET VAN LIERE.
`
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`2. AS SUPPORTED AND VERIFIED BY ALL OF THE ATTACHED CORRESPONDENCE, AS WELL AS, ALL
`OF THE NUMEROUS PHONE CONVERSATIONS I HAVE BEEN STRESSFULLY FORCED TO ENDURE, I
`HAVE BEEN TRYING, DESPERATELY, TO GET SOMEONE AT HOUSEHOLD FINANCE TO RECOGNIZE
`OUR DRASTICIALLY CHANGED FAMILY FINANCIAL CIRc*msTANCES AND TO PROVIDE ME IN
`WRITING WITH SOME REASONABLE REPAYMENT PLAN THAT WOULD WORK WITH OUR FAMILY
`BUDGET. AFTER BEING UNEMPLOYED FOR AN EXTENSIVE PERIOD OF TIME, I AM CURRENTLY
`AND SEVERELY UNDEREMPLOYED IN AN ENTRY LEVEL POSITION THAT PAYS, ON AVERAGE, A
`SMALL FRACTION OF WHAT I ONCE MADE WORKING WITHIN THE PROFESSION THAT I WAS
`TRAINED FOR WHEN HOUSEHOLD FINANCE FIRST BEGAN RECRUITING AND SOLICITING MY
`BUSINSESS {IN FACT WHEN THEY FIRST BEGAN AGGRESSIVELY AND INSISTENTLY PURSUING MY
`BUSINESS MORE THAN TWELVE YEARS AGO THEY ACTUALLY CAME TO MY PERSONAL OFFICE
`TRYING TO ENTICE ME TO CONSIDER THEIR OFFERS OF UNSECURED CREDIT WITH ONLY MY
`GOOD INCOME AT THE TIME TO BACK IT UP; INTERESTINGLY, WHERE ARE THESE VERY HELPFUL
`HFC REPRESENTATIVES WHEN I WAS TRYING FOR THE LAST FOUR PLUS YEARS TO GET SIMPLE
`INFORMATION AND SOME TYPE OF REASONABLE PAYMENT PLAN). MY MEAGER CURRENT
`INCOME, WHICH IS LESS THAN ONE—FIFTH OF WHAT WE ONCE MADE, DOES NOT EVEN COVER
`BASIC WEEKLY HOUSING, FOOD, ELECTRIC, HEATING AND OTHER SUSTENANCE OBLIGATIONS,
`MUCH LESS THE OTHER OBLIGATIONS OF MORTGAGES, TUITIONS,OUR TWO SON’S MEDICAL
`NEEDS WITH CHRONIC ILLNESSES, AND OTHER DEBTOR OBLIGATIONS. AS DETAILED IN TH ESE
`ATTACHMENTS, WHICH THE COURT IS LMPLORED TO READ FULLY AND THOROUGHLY (SINCE I
`WAS UNSUCCESSFUL IN EVER GETTING ANY HOUSEHOLD FINANCE REPRESENTATIVE,
`INCLUDING "EXTERNAL” DEBT COLLECTOR CLIFF BABco*ck — WHO I HAVE NO IDEA WHO HE IS,
`WHO HE REPRESENTS AND HAVE NEVER HEARD FROM BEFORE RECEIVING THIS COMPLAINT
`AND IS SURELY NOT OWED ANY MONEY DESPITE WHATEVER HE MAY HAVE PAID HOUSEHOLD
`FINANCE TO STRESSFULLY HARRASS US INTO PAYING WHATEVER HE CAN GET -TO READ,
`ACKNOWLEDGE AND RESPOND TO IN ANY REASONABLE FASHION), I DO NOT HAVE ANY
`RESOURCES WHATSOEVER TO FULFILL THE OUTRAGIOUS, UNWARRANTED AND
`UNSUBSTANTIATD DEMANDS TO PAY IN FULL $15,800.00 FOR A DISPUTED ACCOUNT THAT BY
`THE DETAILS OF THE VERY EXHIBIT (WHICH IS ALSO 0F TOO SMALL OF TYPE FOR ANY SEEING
`PERSON TO EVEN READ AND HAS OBVIOUSLY BEEN SIGNIFICANTLY DOCTORED AND ALTERED BY
`SOMEONE BEFORE IT WAS PROVIDED TO THE COURT AND THE DEFENDANT) THAT THE
`PLAINTIFF’S ATTORNEY PROVIDED IS CAPPED BY A $10,000 LINE OF CREDIT THAT WAS
`UNMISTABLY AND UNQUESTIONABLY ESTABLISHED VOLUNTARILY BY THE PLAINTIFF (WITHOUT
`ANY FURTHER EVIDENCE OF ANY KIND THAT THE ACCOUNT IN DISPUTE WAS EVER INCREASED
`WITH ANY APPROPRIATE AUTHORIZATION, SIGNATURE OR APPROVAL OF THE DEFENDANT).
`IN
`GOOD FAITH, IN AN EFFORT TO STRIKE A REASONABLE RESOLUTION OF THIS ENTIRE
`UNCONSCIONABLE MESS, I PAID SEVERAL PARITAL PAYMENTS, AS ENUMERATED AND
`DOCUMENTED BELOW AND IN THE ATTACHMENTS OVER SEVERAL MONTHS BASED PRECISELY
`ON WHAT VARIOUS HFC ”REPRESENTATIVES" INSTRUCTED ME TO PAY VERBALLY OVER THE
`PHONE, AND YET DESPITE ALL OF THE VERBAL PROMISES AND GUARANTEES I RECEIVED OVER
`THE PHONE BY THESE SO-CALLED REPRESENTATIVES, I NEVER RECEIVED EVEN ONE REPAYM ENT
`PLAN THAT WAS EVER AFFORDED ME FOR MY CONSIDERATION DESPITE MY REPEATED
`
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`

`7
`
`REQUESTS AND PRO-ACTIVE PLEADINGS WITH HFCTO DO SO, WHICH ARE ENUMERATED
`BELOW. WITH THE ECONOMIC DEPRESSION CREATED BY LARGE FINANCIAL INSTITUTIONS LIKE
`HOUSEHOLD FINANCE HITTING ME AND MY FAMILY OF SEVEN SQUARELY AND DIRECTLY WE
`HAVE EXHAUSTED ALL OF OUR SAVINGS, LIFE INSURANCE AND RETIREMENT FUNDS TRYING TO
`KEEP UP WITH OUR BASIC MONTHLY BILLS AND OBLIGATIONS FOR A FAMILY WITH FIVE KIDS,
`THREE OF WHOM STILL LIVE AT HOME, INCLUDING TWO THAT ARE IN COLLEGE AND ONE THAT
`WILL NEED TO GO TO COLLEGE IN THE NEXT COUPLE OF YEARS USING WHATEVER FINANCIAL
`AID, GRANTS AND LOANS THEY COULD PUT TOGETHER. WITH MY UNEMPLOYED STATUS (FOR
`THE FIRST TIME IN MY MORE THAN THIRTY—- FIVE YEAR WORK CAREER) PAINFULLY LASTING
`FOR NEARLY AYEAR AND NOW WORKING IN ENTRY LEVEL POSITIONS OUTSIDE THE FIELD i WAS
`TRAINED FOR, WE HAVE BASIC FOOD, HOUSING, MEDICAL AND EDUCATIONAL OBLIGATIONS
`THAT FAR EXCEED OUR MONTHLY INCOME. THE VEHICLES WE HAVE ARE MORE THAN TWELVE
`(12) YEARS OLD WITH MORE THAN 180,000 MILES ON EACH OF THE TWO VEHICLES; WE HAVE A
`HOUSE WE CANNOT SELL OR REFINANCE; AND WE SCAMBLE EVERY DAY AND MONTH TRYING
`TO GETiBY AS BEST WE CAN ON WHAT WE HAVE TO LIVE ON EACH MONTH. FOR MORE DETAILS
`ON MY FINANCIAL PREDICAMENT PLEASE, AGAIN, REVIEW ALL OF THE EFFORTS I HAVE MADE
`CONTINUALLY TO BEG FOR THE UNDERSTANDING AND COOPERATION OF HOUSEHOLD FINANCE
`TO WORK WITH THIS SITUATION .IUST AS OUR OTHER CREDITORS HAVE DONE, INCLUDING
`MONTGOMERY COUNTY IN PUTTING US ON A MONTHLY PROPERTY TAX DELINQUENCY
`PAYMENT PLAN, VECTREN WITH A DELINGUENT/PARTIAL PAYMENT ENERGY PLAN, THE
`FEDERAL AND STATE GOVERNMENTS FOR DELINGUENT INCOME TAXES OWNED, CITIGROUP
`(SEE ATTACHED EXHIBIT), U.S. BANK, AT&T AND SEARS CREDIT CARD AND SEVERAL OTHERS
`WHO HAVE PRO—ACTIVELY AND THOUGHTFU LLY CHOSEN TO RECOGNIZE AND WORK WITH OUR
`SITUATION AS IT ACTUALLY EXISTS (NOT AS THEY OR US WISH IT TO BE). WHILE NOT
`INUNDATING THE COURT WITH MY ENTIRE FILE, I HAVE ATTACHED THE FOLLOWING LETTERS
`AND MY CERTIFIED REQUESTS TO HOUSEHOLD FINANCE RESPONDING TO EVERY
`COMMUNICATION THEY EVER SENT ME, ALONG WITH SEVERAL MONTHS OF REQUESTED
`PARTIAL PAYMENTS I HAVE MADE IN AN EFFORT TO RESOLVE THIS MATTER, WHICH ONLY
`RESULTED IN THEM CHARGING HIGHER AND HIGHER INTEREST RATES, LATE CHARGES AND FEES
`AND OTHER PENALTIES THAT ONLY EXACERBATED THIS ALREADY DISPUTED ACCOUNT AND THE
`UNSUBSTANTIATED AMOUNT THEY SAY IS NOW DUE. THIS CORRESPONDENCE VIA MAIL
`BEGAN ALMOST IMMEDIATELY AFTER WE MISSED OUR FIRST FULL MINIMUM PAYMENT DUE TO
`OUR DETERIORATING FINANCIAL CIRc*msTANCES WITHOUT ANY WARNING OR NOTICE;
`(A) LETTER OF OCTOBER 1, 2009 MAKING A PARTIAL PAYMENT AND REQUESTING
`ASSISTANCE FROM HFC FOR, IN THEIR WORDS -— "A MUTUALLY ACCEPTABLE
`PAYMENT ARRANGEMENT”, WHICH NEVER CAME AND WAS COMPLETELY IGNORED;
`(B) LETTER OF NOVEMBER 15, 2009 AGAIN MAKING A PARTIAL PAYMENT AND, ONCE
`MORE, ASKING FOR THE HFC PAYMENT OPTIONS IN WRITING THAT WOULD FIT OUR
`BUDGET, BUT WHICH WERE NEVER PROVIDED OR ACKNOWLEDGED IN ANY WAY;
`(C) LETTER OF MAY 6, 2010 TO MS. MARGARET VAN LIERE OF HFC, RESPONDING AS SHE
`HAD REQUESTED WITHIN TEN (10) DAYS SEEKING TO {AGAIN IN HER WORDS) ”MAKE
`SUITABLE PAYMENT ARRANGEMENTS”, WHICH SHE NEVER RESPONDED TO AND
`
`
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`

`

`FOLLOWED UP BY SENDING IT TO ATHIRD PARTY FOR UNWARRANTED ACTION AND
`HARRASSMENT IN CLEAR VIOLATION OF THE U.S. FAIR DEBT COLLECTIONS
`PRACTICES ACT FAILING TO OBSERVE EVEN THE MOST BASIC DUE PROCESS RIGHTS
`
`3.
`
`OF THE DEBTOR; AND
`(D) CERTIFIED/REGISTERED LETTER OFIUNE 18,2010 TO CLIFF BABco*ck IN RESPONSE
`TO HIS PHONE CALL OF MAY 27, 2010 AND HIS LETTER OF THE SAME DAY OF MAY
`27, 2010 IN WHICH I WAS SUPPOSED TO BE GIVEN THIRTY (30} DAYS TO RESPOND
`AND , IN FACT, MR.BABco*ck ILLEGALLY AND PREMATURELY FILED HIS LAWSUIT AND
`COMPLAINT AGAINST ME THREE (3) DAYS LATER ONJUNE 1, 2010, IN CLEAR
`VIOLATION OF THE U.S. FAIR DEBT COLLECTIONS PRACTICES , THE U.S. FAIR CREDIT
`REPORTING ACT AND THE MOST BASIC OF THE RULES AND REGULATIONS
`PROMULGATED BY THE U.S. FEDERAL TRADE COMMISSION TO PROCTECT DEBTORS
`AGAINST THESE VERY TYPES OF ABUSIVE ACTIONS BY CREDITORS AND THEIR THIRD
`PARTYJUNK DEBT BUYERS/COLLECTORS.
`IN CLEAR VIOLATION OF THE U.S. FAIR DEBT COLLECTIONS PROTECTION ACT, NONE OFWHATI
`REQUESTED IN WRITING WAS EVER PROVIDED INCLUDING, BUT CERTAINLY NOT LIMITED TO,
`THE LACK OF ANY RESPONSE WHATSOEVER TO THE REQUEST THAT CLIFF BABco*ck PROVIDE
`SIMPLE VALIDATION AND VERIFICATION OF THE DEBT THEY SAID | OWED THEM AND MY
`SIGNATURE VERIFYING AND LEGALIZING THIS SUPPOSED OBLIGATION THAT I HAVE TO THEM.
`IN MAKING THIS REQUEST AND IN ALL OF THE OTHER INN UIVIERABLE VERBAL
`‘
`COMMUNICATIONS I HAVE STRESSFULLY ENDURED IN THIS MATTER ON A DAILY AND
`SOMETIMES TWICE A DAY BASIS, DID I EVER REFUSE TO PAY A VALIDATED DEBT THAT I OWED.
`ADDITIONALLY, AS YOU CAN SEE FROM THESE ATTACHMENTS, NOT ONLY WERE THE ACTIONS
`AND COMMUNICATIONS OF HOUSEHOLD FINANCE AND THEIR COLLECTION AGENT IN
`VIOLATION OF THE TERMS, CONDITIONS AND REQUIREMENTS OF THE U.S. FAIR DEBT
`COLLECTIONS PROTECTION ACT, BUT THEY WERE THOROUGHLY INDEFENSIBLE. AT NO TIME
`DID I EVER RECEIVE ANYTHING FROM ANYONE VERIFYING ANY DEBT OWED, OR HOW THEY
`ARRIVED AT THE AMOUNT THAT IS NOW BEING DEMANDED. THE FAIR DEBT PRACTICE ACT
`REQUIRES THAT ALL COLLECTION EFFORTS CEASE, UNTIL A DISPUTED DEBT IS VALIDATED AND
`THE INFORMATION REQUESTED BE SUPPLIED TO THE ALLEGED DEBTOR.
`4. AS FURTHER EVIDENCE OF HOW AGGREGIOUS, STRESSFUL , DISRUPTIVE AND UN FAIR THIS
`ENTIRE PROCESS HAS BEEN I WOULD CALL YOUR ATTENTION TO THE HFC LETTER OF MARCH 4,
`2010, WHERE FOR THIS DISPUTED ACCOUNT THAT THEY ESTABLISHED A $10,000 CREDIT LIMIT
`FOR, THEY OFFER TO SETTLE THE ENTIRE SORDID AFFAIR FOR $11,059.90 USING ATAX REFUND.
`WITH THE FEDERAL GOVERNMENT ACTUALLY DEMANDING MORE MONEY FROM US FOR THE
`RETIREMENT ACCOUNTS WE WERE FORCED TO CASH IN TO CONTINUE TO LIVE AND SURVIVE,
`AND RECOGNIZING THAT WE CANNOT EVEN PAY THE SEVERAL HUNDRED DOLLARS A MONTH
`THAT HFC HAD RUN THE MONTHLY AMOUNTS UP TO ON THIS DISPUTED ACCOUNT THROUGH
`THEIR MAXIMIZING OF THE INTEREST CHARGES, LATE FEES, AND OTHER PENALTIES AND
`CHARGES THEY HAVE REGULARLY IMPOSED ON THIS ALLEGED BALANCE OWING, HOW DO THEY
`POSSIBLY AND REASONABLY THINK WE WOULD EVER COME UP WITH MORE THAN $11,000 IN A
`ONE-TIME “SETTLEMENT PAYMENT” TO THEM. AS THE ONE AND ONLY THINKING VOICE AND
`
`

`

`MIND OF REASON IN THIS UNWARRANTED COMPLAINT, THE COURT MUSTPUT AN END TO THIS
`UNMERCIFUL AND UNWARRANTED HARRASSMENT BY DISMISSING THIS COMPLAINT
`IMMEDIATELY AND PROMPTLY, PARTICULARLY IN VIEW OF THE FACT THAT HFC HAS ALREADY
`RECEIVED MORE THAN $33,000 FOR THIS DISPUTED DEBT, WHICH IS MORE THAN THREE TIMES
`THE AMOUNT THAT WAS EVER SUPPOSEDLY LOANED IN THIS MATTER.
`AS HON EST, HARDWORKING PEOPLE WITH A LARGE FAMILY TO SUPPORT IN THE MIDST OF A
`DEPRESSION, WE HAVE ALWAYS DONE EVERYTHING WE CAN TO PAY WHAT WE CAN ON ANY
`LEGITIMATE OBLIGATIONS AND REQUIREMENTS WE HAVE, INCLUDING, AS MENTIONED ABOVE,
`MORE THAT $33,000 WE HAVE ACTUALLY PAID HOUSEHOLD FINANCE OVER THE LAST TWELVE
`PLUS YEARS (WHICH, AGAIN,
`IS MORE THAN THREE TIMES THE ORIGINALLY, AND ONLY,
`APPROVED CREDIT LIMIT ESTABLISHED BY HOUSEHOLD FINANCE), WHICH IS TRULY MORE THAN
`‘ WE CAN AFFORD TO PAY WITH OUR HOUSE IN JEOPARDY AND ALL OF OUR OTHER ASSETS
`LIQUIDATED AND SOLD OVER THE LAST THREE YEARS (INCLUDING ALL OF OUR SAVINGS
`ACCOUNTS, LIFE INSURANCE MONIES AN DRETIREMENT ACCOUNTS), SINCE I FIRST LOST MY JOB
`AND OER FINAN