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Thank you for using our forum. My name is ***** ***** I would like to assist you.
I have reviewed your post above and it appears that you have a home that is located in an HOA.
The HOA fees are in arrears and the Association is filing suit to foreclose on the property.
You would like to have the matter dismissed because the HOA did not allege that the court has jurisdiction.
Unfortunately, this is not a basis for a dismissal - the HOA has likely listed the address of the property in its complaint, giving the court jurisdiction over the matter as "in rem" jurisdiction - the court action taking place in the county court where the property is located. There is no requirement for the plaintiff to make any separate or additional verbiage in its complaint.
You would like to have the matter dismissed based on the way the fees are claimed in the complaint.
Again, while the complaint may have alleged the fees in a lump sum - this is not a basis to dismiss the complaint (at least not in the pleading stage). You can argue that the charges claimed are not appropriate during the litigation (so you can contest the total amount owed during the lawsuit - and even file an answer to the complaint that contradicts the amount owed - but the court is not going to dismiss the action in the pleading stage because there is no itemized list (there isn't a requirement for the plaintiff to do so in the pleading stage).