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Question

How do I find the Kansas State laws?I am verifed answer to complaint. Also I need to know the State Department of Financial and Professional Regulation.          

                     & nbsp;                                                                                           Thanks Brenda
                     & nbsp;                                                                                                       Caney,Kansas

Submitted: 209 days and 21 hours ago.
Category: Legal
Value: $30
Status: CLOSED
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Optional Information

Caney, Kansas

Already Tried:
I tried Google and look than I came across you guys.I was given this Petition.Left on my door and did not find it till a week later.We have back door enter only.So the day trash goes out I found it.I am doing a Verified Answer to the Complaint.

Posted by Law Pro 209 days and 21 hours ago.

Info Request

I'm not sure what's going on here. Could you explain further? Thank you.

209 days and 21 hours ago.

Reply

Portfolio Recovery Associates.Got attorneys Burns,Burns,Walsh out of Lyndon,Kansas debt collector.I AM FEELIN OUT A DISPUTE THE PETITION.

Posted by Law Pro 209 days and 21 hours ago.

Info Request

Is this a suit about credit card debt or what? If it's credit card debt - when was the last time you made a payment? Did they attach a copy of the contract?

209 days and 21 hours ago.

Reply

YES IS A CREDIT CARD DEBT.OVER A YEAR AGO.ON THERE IS NO COPY OF THE CONTRACT.

Accepted Answer

The statute of limitations on debt in Kansas limits the time you can be sued for a debt:

 

Oral Contract: 3 years

Written Contract: 6 years

Promissory Note: 5 years

Open-Ended Accounts: 3 years

 

Credit card debt is considered open-ended accounts - therefore, they must file suit within 3 years after your breach of the credit card agreement. As you stated that it was about 1 year ago - they are well within the statutory time frame within which to file suit on the matter.

 

What you will have to do is answer the complaint and then file a request for production of documents.

 

Here are sample complaints, answer, and requests for production of documents:

 

COMPLAINT

1) Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices

at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 .

2) Defendant is adult individual(s) residing at the address listed

below:

Sam Smith

XXXX XXXXXXXXX XX Anywhere, USA 15044

3) Defendant applied for and received a credit card bearing the

account number XXXXXXXXXXXX1987 .

4) Defendant made use of said credit card and has a current balance

due of $6119.32 , as of August 27, 2008 .

5) Defendant is in default by failing to make monthly payments when

due. As such, the entire balance is immediately due and payable to Plaintiff.

6) Plaintiff is entitled to the addition of interest at the rate of

28.100% per annum on the unpaid balance from August 27, 2008 . A copy

of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and

made a part hereof.

7) Although repeatedly requested to do so by Plaintiff, Defendant has

willfully failed and/or refused to pay the balance due to Plaintiff.

 

Wherefore, the Plaintiff prays for judgment in its favor and

against Defendant , Sam Smith , INDIVIDUALLY , in the amount

of $6119.32 with continuing interest thereon at the rate of 28.100%

per annum from August 27, 2008 plus costs.

 

ANSWER TO COMPLAINT

1) After reasonable investigation, the allegations contained in paragraph 1 of Plaintiff's Complaint are denied and strict proof to the contrary are demanded at trial.

2) Admitted.

3) Denied. To the contrary the allegations contained in paragraph 3 of Plaintiff's Complaint are specifically denied and strict proof to the contrary are demanded at trial. In further answer to Plaintiff's Complaint, Plaintiff has failed to attach a copy of the signed contract.

4) Denied. To the contrary the allegations contained in paragraph 4 of Plaintiff's Complaint are specifically denied and strict proof to the contrary are demanded at trial. In further a answer to Plaintiff's Complaint, Plaintiff has failed to attach any statements showing use of said credit card by Defendant.

5) Denied. To the contrary the allegations contained in paragraph 5 of Plaintiff's Complaint are specifically denied and strict proof to the contrary are demanded at trial. In further answer to Plaintiff's Complaint, Plaintiff has failed to produce an executed contract or give any evidence of a verbal agreement between the Plaintiff and Defendant.

6) Denied. To the contrary the allegations contained in paragraph 6 of Plaintiff's Complaint are specifically denied and strict proof to the contrary are demanded at trial. In further answer to Plaintiff's Complaint, Plaintiff has failed to attach a copy of the contract to the Complaint and is fictionally stating such that they are entitled to any interest.

7) Denied. To the contrary the allegations contained in paragraph 7 of Plaintiff's Complaint are specifically denied and strict proof to the contrary are demanded at trial.

 

WHEREFORE, Defendant requests this court to dismiss the Plaintiff's Complaint with prejudice.

NEW MATTER

8) That Plaintiff does not have an original or copy of an executed contract between the Plaintiff and Defendant upon which this suit is brought.

9) That Plaintiff does not have any statements original or otherwise showing purchases and/or payments made by the Defendant upon which this suit is brought.

10) That the agreement or contract if made between the Plaintiff and Defendant and which is strictly denied upon which this action is based is outside the statute of limitations of Pennsylvania for collection thereof.

 

WHEREFORE, Defendant requests that this court dismiss the Plaintiff's Complaint with prejudice.

Respectfully submitted,

 

DOCUMENT REQUEST

1) Copies of any and all contracts between the plaintiff and defendant at any time.

2) Copies of any and all contracts between the plaintiff and defendant that would relate to plaintiff's claim in paragraph 3 of plaintiff's civil complaint.

3) Copies of any and all monthly and/or yearly or annual statements regarding any contracts as between the plaintiff and defendant that would related to paragraph 4 of plaintiff's civil complaint.

4) Copies of any and all contracts between the plaintiff and defendant that would relate to plaintiff's claim in paragraph 3 of plaintiff's civil complaint.

5) Copies of any and all documents which reflect, record, describe, refer or relate to, or contain information concerning defendant is in default as stated in plaintiff's civil complaint paragraph 5.

6) Copies of any and all documents which reflect, record, describe, refer or relate to, or contain information concerning that plaintiff is entitled to the addition of interest at the rate of 28.100% per annum on the annum on the unpaid balance from August 27, 2008 as stated in plaintiff's civil complaint paragraph 6.

7) Copies of any and all documents which reflect, record, describe, refer or relate to, or contain information concerning that plaintiff has repeatedly requested defendant to pay the balance due to plaintiff as stated in plaintiff's civil complaint paragraph 7.

 

Respectfully submitted,

Picture
Expert: Law Pro
Pos. Feedback: 99.0 %
Accepts: 
Answered: 4/25/2009

Attorney

19 years legal practitioner: real estate, collections, estate, civil, business, and criminal law

209 days and 20 hours ago.

Reply

NEED CIVIL Procedures by state kansas

Posted by Law Pro 209 days and 20 hours ago.

Info Request

You have to file the answer - that's clear.

 

Use that answer as an example to answer the complaint they filed - the procedure is identical.

 

What - do you want the statute number or what?

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