Consumer complaint received 2023-12-30
Product: Debt collection — Credit card debt
Issue: Attempts to collect debt not owed — Debt is not yours
Company: Aldridge PIte Haan, LLP (FL)

PART 2 of 4  Reference Aldridge file XXXX for its client XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  filed early XXXX XXXX XXXX RESPONSE OF XXXX  TO XXXX CFPB COMPLAINT
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Dear XXXX XXXX: On behalf of XXXX XXXX, I am responding to your concerns raised through the Consumer Financial Protection Bureau (CFPB). I appreciate you bringing this matter to my attention. We would like to stress compliance is very important to XXXX XXXX and we follow all applicable laws. Your inquiry is also important to us, and it is our goal to serve our customers in a timely and satisfactory manner. We regret any dissatisfaction you may have experienced; however, we must respectfully decline your request for any type of compensation. Since we received a cease and desist request from you, we will adjust your account to stop all future collection calls. However, you will continue to receive legally required statements and we will continue to report the status of your account to the credit bureaus.  Pursuant to the XXXX XXXX Credit Card Agreement, which governs our relationship, you may file a demand for XXXX  with the XXXX XXXX XXXX. Contact information for the XXXX XXXX XXXX can be found at their website  www.adr.org. Thank you for the opportunity to respond to your concerns raised through the CFPB. If you have additional questions regarding this matter, contact me at XXXX XXXX XXXX XXXX I welcome the opportunity to assist you. Respectfully, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

RESPONSE OF ALDRIDGE TO 2 CFPB COMPLAINTS of XXXX
Complaint Numbers: XXXX XXXX XXXX XXXX XXXX  To Whom It May Concern  The complaint filed by XXXX XXXX against Aldridge Pite Haan, LLP (APH) through the CFPB has been forwarded to me for review and response. We take all complaints seriously at APH, and we appreciate the opportunity to address XXXX XXXX concerns. In preparing a response to his complaint, we have reviewed the accounts he identifies and the documentation and information that goes with them. We have also escalated his complaint to our client, XXXX XXXX XXXX XXXX XXXX  has requested a cease and desist with no further written communication. As such, this response is directed to the CFPB and will be submitted in response to XXXX XXXX XXXX XXXX  complaints. XXXX XXXX attached copies of initial written communications (XXXX  notices) for XXXX  accounts. XXXX  of those accounts have been placed with APH for collection (APH account numbers XXXX XXXX XXXX XXXX). The XXXX  account referenced by XXXX XXXX through the attached XXXX notice appears to have been placed with another firm for collection. APH can only respond and provide information regarding the XXXX  accounts that have been placed with it. XXXX  of the XXXX  accounts (APH ## XXXX XXXX XXXX were placed with APH on or about XXXX XXXX XXXX. On XXXX XXXX XXXX, the initial communication/XXXX  notice for accounts numbers XXXX XXXX XXXX were generated and mailed to XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. The XXXX  account (XXXX XXXX) was placed with APH on or about XXXX XXXX XXXX  and the initial communication/XXXX  notice for that account was generated on XXXX XXXX XXXX and mailed to the XXXX XXXX XXXX  address. This is the same address that he provided to the CFPB. The initial communications contained the required XXXX notice language. They were not returned to APH as undeliverable. On or about XXXX XXXX XXXX XXXX XXXX  submitted a complaint through the CFPB portal. XXXX XXXX  provides a lengthy dissertation of his complaints and concerns, and it appears that he was required to submit the complaint through XXXX  separate complaint forms. He therefore has complaint number XXXX and complaint number XXXX XXXX XXXX  indicates that he has submitted a demand for XXXX. APH has not received a copy of the demand. APH asks that XXXX XXXX provide APH with a copy of the demands for XXXX. If XXXX XXXX would like to discuss his accounts further, he can contact APH at XXXX  Because he has requested that a cease and desist be placed on the accounts, he will need to formally withdraw the cease and desist to discuss any of the accounts.

CFPB COMPLAINT # XXXX FOR XXXX FILING XXXX ILLEGAL BARRED LAWSUITS ON OR AFTER XXXX DESPITE IDENTICAL PENDING XXXX XXXX CASES PENDING SINCE XXXX XXXX  
YOUR COMPLAINT
From: XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX I write to complain about the illegal unserved lawsuits filed by XXXX XXXX  in the last few days against me despite my multiple XXXX  cases which requires all disputes to be resolved in XXXX with the XXXX  pursuant to the filed XXXX  provisions. I will not tolerate frivolous barred debt collector tactics and lawsuits in violation of numerous statutes including the FDCPA. I demand that XXXX  immediately DISMISS any Null and Void lawsuits filed recently, months after my arbitration cases were filed. Furthermore, any summonses and documents sent to process servers must be immediately retrieved to prevent service attempts and harassment. I intend to file Supplemental Demands and Claims and/or new arbitration cases for this recent development once the extent of the filed lawsuits become known. Unless any lawsuits are dismissed in XXXX hours, I plan to file Complaints against violating attorneys with the XXXX  Bar plus seek redress to compel forced binding arbitration on all claims by filing a petition in the U.S. District XXXX XXXX XXXX XXXX XXXX XXXX Division and/or seek an Emergency XXXX  to enjoin barred lawsuits by XXXX. I know my best option, although more expensive, is to file a federal lawsuit as it will certainly stay all litigation proceedings until arbitration awards are issued which will allow the federal court to ultimately review any awards with exclusive jurisdiction. However, I ask Manager XXXX to advise me of the availability of an Emergency Arbitrator, to be paid by XXXX, for a one time decision to prevent litigation that must be resolved in pending XXXX. I also ask Manager XXXX to advise the parties of the issues and consequences that may arise by XXXX filing multiple lawsuits after the filing of XXXX  cases. XXXX  insane conduct will certainly be seen by the XXXX  as just another type of frivolous and illegal activity which will increase estimated XXXX  fees and a certain award in favor of claimant. XXXX  needs to get its ducks in a row before multi jurisdictional litigation increases. I also ask XXXX  to immediately advise me and Manager XXXX of how many individual credit card lawsuits XXXX intends to file in state courts against me. I will still be out of state for the next XXXX days without access to my files to adequately respond. I expect XXXX  XXXX  can immediately do the right thing and force dismissal of lawsuits and prevent wasting resources by filing new lawsuits. Sincerely, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX
Below you will find details of illegal and unethical conduct of attorneys for XXXX XXXX for filing illegal and barred state court cases in XXXX  on or about XXXX despite the facts that I filed multiple XXXX  cases with XXXX  against XXXX XXXX during XXXX XXXX  which have been pending with the XXXX  ever since for the identical disputes.  The XXXX  has given XXXXtill XXXXto explain otherwise I will seek an Emergency XXXX, petition a USDCto compel arbitration with existing arbitration cases and stay the litigation pending an XXXX  award.  Complaints against violating attorneys will also be filed with the XXXX  Bar for intentional illegal conduct. Your Code of Conduct requires your attorneys to comply with laws and the spirit of laws both of which have been deliberately violated. I trust that you can investigate your attorneys and take disciplinary action against them. I will obtain injunctions and pursue contempt proceedings if federal orders are violated if the insane litigation cases are not immediately withdrawn, discontinued and dismissed as set forth herein. I hope the vicious and unprovoked retaliatory attack using barred state courts will be declared null and void ab initio so that you will not need to take action. Sincerely, XXXX XXXX XXXX  claimant.


XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  
	
We have received the below correspondence. Please omit the XXXX XXXX team and any other XXXX team members from future communications. Please direct all correspondence to me, as the attorney of record for XXXX for this proceeding.

Thank you,


toXXXX


I need to immediately know the exact name of the required LEAD ATTORNEY and other attorney of record in any pending XXXX XXXX state court lawsuits filed against me illegally by XXXX XXXX with their statutory required email addresses so that true and correct copies of pleadings that I will file can be delivered to them as participants participating in electronic filing service via e-filing portal only. You should now know this as part of your required investigation. As you should know, service can be made via the e-filing portal but I need the exact email addresses to take additional steps to assure documents are received. While I have been blocked from copying others at XXXX, sending communications to a party represented by counsel is even worse than contempt of court resulting in up to XXXX figure sanctions. Even worse, XXXX intentionally filing lawsuits against me in violation of my cease and desist notices while XXXX  has known that I have pending XXXX  cases with the XXXX  is far worse and possibly the worst unethical conduct an attorney can take. While I can appreciate your desire to exclusively receive communications, your have been unconscionably negligent by not taking absolute control of your client to prevent the frivolous and barred vexatious multiplicity of proceedings by directly allowing state court cases to be filed despite the XXXX  agreements and pending XXXX  cases for identical accounts. You have dropped the ball and avoiding others to audit you is counterproductive to compliance and prevention of illegal state court filings. Frankly, there are too many cooks in the kitchen without diligent and necessary oversight all seeking fees from XXXX.  As XXXX  Attorney responsible for the disputes, I insist that you immediately personally file a pleading with the state court judges, clerks, magistrates and judicial assistants in each cases dismissing, discontinuing, withdrawing and permanently closing any state court cases specifically disclosing in said filing that the matters are subject to valid and binding arbitration agreements and that the matters have been pending with the XXXX  since XXXX XXXX so the state courts do not have jurisdiction over the disputes. You must also immediately obtain a return of documents from process servers as any attempt of service constitutes serious illegal conduct.  Do not rely on robots and others to meet your obligations to immediately get the state court cases declared null and void ab initio and permanently closed and sealed. Dont rely on the attorneys filing the lawsuits. File pleadings today to hopefully avoid personal responsibility unless this was your plan all along. I was a little surprised that you did not file a counterclaim but maybe it was your personal plan orchestrated to file XXXX different state court cases while identical arbitration cases were pending for months. Mistakes happen but the right thing requires immediate attention without excuses or coverups. XXXX  case Manager XXXX  now understands fully the situation and has graciously given you till XXXX XXXX to respond and take action without trampling on the jurisdiction of the XXXX. Dont be stupid like the disgraced Presidents of XXXX  and XXXX. This is a no brainer requiring simple mandatory dismissal of state court cases. Dont alienate the XXXX  and XXXX arbitrators with delays and excuses. Do the right thing and move on. Sincerely, XXXX XXXX XXXX XXXX XXXX

CFPB COMPLAINTS TO CRAS DISPUTING XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  

YOUR COMPLAINT
I write to XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  accounts AND request that you include the below CONSUMER STATEMENT for Each of the XXXX XXXX  accounts which means there must be XXXX account specific consumer statements for each of my XXXX XXXX accounts incorporated with data for each of the XXXX accounts. I have filed numerous disputes for over XXXX months with every CRA and directly with XXXX  disputing each of the XXXX accounts. However, every time the required DISPUTE status is entered in my credit reports, XXXX  deleted them and every CRA willfully violated its Facially False Data prohibitions of the CFPB. Such violations are deemed willful by the CFPB and carry statutory damages of XXXX per violation per account per event plus 10-80 times punitive damages (see Saunders, 526 F.3d 142) making damages of multi million dollars per account. In XXXX XXXX, I filed multiple consumer demands with the XXXX XXXX XXXX XXXX claiming entitlement to over XXXX in statutory and punitive damages per account pursuant to Synchronys arbitration agreement. I have attached multiple letters from XXXX  to evidence arbitration cases along with pages XXXX XXXX and XXXX of each claim regarding federal jurisdiction about liability if matters were filed in a U.S. XXXX XXXX XXXX has retained counsel and the multiple XXXX  cases are awaiting fee payments to XXXX  by XXXX  plus its Answers due shortly. I have not filed any federal court case against any CRA yet in hope of obtaining FCRA compliance, especially account deletions. I owe XXXX XXXX and it owes me millions but my credit reports are inaccurate. Liability continues to increase for XXXX  and every CRA by failing to report accounts as disputed and failing to report the date of account closure by consumer. Please investigate and update your reports and delete accounts to mitigate damages. I will surely Subpoena CRA records so I expect that the investigation process will be thorough and complete. I ask that you include the following account specific consumer statement for each of the XXXX accounts. -CONSUMER STATEMENT For each of my XXXX XXXX XXXX accounts, XXXX  is liable to me for statutory and punitive damages for every account for repeated WILLFUL FCRA violations exceeding XXXX. In XXXX XXXX, I filed multiple 25+ page Consumer Demands with the XXXX XXXX XXXX XXXX detailing specific calculations of its multi-million dollar liability for each account. XXXX cases are pending awaiting payment of billed XXXX  fees and Answers in each case by the XXXX  deadlines. I insist on 100% compliance with the FCRA, FDCPA and other statutes and I will continue to file XXXX  cases with the XXXX  or XXXX  against violators pursuant to arbitration agreements or otherwise in Federal Court if no arbitration provisions exist.
MULTIPLE CFPB COMPLAINTS INCLUDING XXXX TO XXXX  AND DEBT COLLECTORS 

 It should be a NO-BRAINER that you and your predecessors and successors in interest MUST UNCONDITIONALLY and PERMANENTLY STOP, CEASE AND DESIST ALL COLLECTION EFFORTS on the disputed purported debt to mitigate damages. Its not rocket science, Its not brain surgery, Its a piece of cake and Its a walk in the park are common phrases that describe concepts or tasks that are easily understood or performed that are certainly applicable here. Dont be STUPID!! You have no viable ALTERNATIVE! Tell the CFPB in your required response that you permanently cease all collection efforts with a notation that an XXXX  filing, if one exists and is applicable, is the only permissible future communication!!! If an XXXX  agreement exists, please be absolutely clear and dont directly or indirectly wrongly threaten or imply filing a prohibited court action or lawsuit as it would be considered a FDCPA violation intended to harass, threaten and abuse!!!

WHEREFORE, Consumer-Claimant XXXX XXXX respectfully requests that the XXXX  determine and disclose the appropriate award deemed just proper and equitable in favor of XXXX, which amount may certainly far exceed XXXX, and enter an award against XXXX, based upon the first set of facts, in an amount equal to the appropriate award but not to exceed the maximum XXXX amount sought in total in this case including: 
(1)Statutory Willful FCRA, FDCPA, and other statutory and alternative relief, including substantial punitive damages, available to the Arbitrator under his or her Inherent Powers due to XXXX  willful and deliberate violating the XXXX XXXX XXXX  and subsequent CEASE and DESIST Notices and other egregious conduct but in no event more than maximum XXXX sought in this case in total;
(2) Declaring XXXX  claims for this credit card account extinguished, uncollectible and null and void ab initio;.
(3)Directing XXXX  to forthwith permanently delete this XXXX  account from every one of XXXX  credit reports or mark the account as paid as agreed without inclusion of any negative or derogatory data of any kind.  

CLAIM # 2 - Statement of the Facts and Law and Relief Requested
On XXXX XXXX XXXX XXXX, by its attorneys XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX firm, filed 2 frivolous, ROBO, fraudulent, barred, malicious, harassing, extortionate, illegal, bad faith, racketeering lawsuits for XXXX  credit card accounts XXXX XXXX XXXX (illegally disclosing prohibited card numbers) against XXXX in state court despite the XXXX  CEASE and DESIST Notices received by XXXX  and all of the communications and known XXXX XXXX XXXX XXXX XXXX cases since XXXX XXXX  Further, on XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX) filed a frivolous, ROBO, fraudulent, barred, malicious, harassing, extortionate, illegal, bad faith, racketeering lawsuits for XXXX XXXX XXXX XXXX XXXX (illegally disclosing prohibited card numbers) against XXXX in state court despite the XXXX CEASE and DESIST Notices received by XXXX  and all of the communications and known XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX.  The XXXX XXXX lawsuits were filed in state court in XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX.  Each of the XXXX prohibited state court lawsuits contained a copy of XXXX  purported credit card agreement and XXXX  Provisions to evidence that disputes were subject to XXXX  XXXX  Provisions.  However, XXXX  above counsel deliberately CONCEALED the existence of the XXXX XXXX XXXX XXXX XXXX  cases actively pending since early XXXX XXXX  to fraudulently induce the Clerk of the state court to accept the cases for filing and assign the cases to XXXX separate judges to boot.  Should such counsel be fired by their law firms?  Should XXXX  fire the law firms?  Should XXXX  and the law firms refer the attorneys to the XXXX  Bar for disciplinary proceedings? Should XXXX XXXX XXXX XXXX XXXX XXXX XXXX  be likewise fired and/or disciplined?  XXXX even wrote trying to negotiate the resolution of the criminal state court prohibited cases by asking that XXXX  cases be consolidated despite repeated rejection of consolidation by XXXX. XXXX  does NOT NEGOTIATE with filers of prohibited lawsuits known to be illegal!!!!! XXXX  became aware of such lawsuits the day after filing from daily USPS notices of copies of all daily mail sent to XXXX  daily before XXXX such that mailings documenting pending case filings by attorneys advertising for clients constitutes separate and distinct communications barred by the XXXX CEASE and DESIST Notice and the pending XXXX  cases which totally barred lawsuits as cases cannot be pending in both courts and XXXX  in light of previously filed XXXX  cases involving identical matters. Mailings from The XXXX XXXX XXXX XXXX  contained the exact case number on the front of the envelope constituting an unacceptable FDCPA and other violations. Mailings from C and C Consulting not only contained the XXXX case numbers but the caption XXXX XXXX XXXX XXXX XXXX all visible in the front of the each of the XXXX envelopes in further violation of multiple sensitive data statutes.  Similarly, envelopes from XXXX XXXX, Attorney at Law in his advertisement contained XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX visible from the front of each envelope.  USPS notices before XXXX  were also received for each case from Law Offices of XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX etc.  Copies of pleadings and other prohibited sensitive data is included in advertisements which XXXX  is liable for multiple separate and distinct FDCPA and other violations caused by filing the barred lawsuits while identical XXXX  Arbitration cases have been filed for XXXX  months with Cease and Desist Notices filed over XXXX  months prior on XXXX. XXXX has been awaken every day before XXXX by the frivolous communications of lawsuits which were barred by the XXXX CEASE and DESIST notice such that all 50+ communications constitute separate FDCPA and other willful violations to harass and retaliate. When a lawsuit is filed where a valid arbitration provision is enforceable, such action can be simply and effectively automatically stayed by moving to compel binding arbitration in state court or petitioning the Federal Court to stay litigation pending an award in arbitration pursuant to XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX.  However, since XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX months before the filing of the barred cases, the lawsuits are Null and Void ab initio as nothing can be compelled as cases are already in active arbitration and the identical dispute cannot be both litigated and arbitrated at the same time.  While XXXX  counsel XXXX XXXX XXXX XXXX  continues to get DENIED her XXXX  requests to consolidate the XXXX XXXX cases, she became frustrated and conspired with Aldridge and XXXX  and orchestrated and permitted the filing of XXXX XXXX XXXX XXXX XXXX by XXXX separate lawfirms to be assigned to XXXX separate state court judges which is inconsistent with her request to consolidate the NOW pending XXXX XXXX XXXX cases against XXXX  filed by XXXX.  XXXX  could have merely filed a one sentence counterclaim, without filing fees, but XXXX multiple counsel of XXXX XXXX  Aldridge and XXXX  conspired and maliciously filed XXXX separate cases, spending court and other fees of at least XXXX ($500 in each case) to vexatiously multiply the proceedings with prohibited state court cases to harass and bankrupt XXXX. Each of the XXXX XXXX XXXX XXXX XXXX state court cases constitutes a RICO activity and other activity referred to previously.  XXXX  highest legal Officer XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXr has been apprised as stated above in emails to him and XXXX  but no action has been taken to cease the RICO and extortionate criminal conduct.  Furthermore, every communication by XXXX  after the XXXX CEASE and DESIST notices, including notices of Aldridge and XXXX  and the illegal pulling of XXXX  credit report all justify a RICO activity and extortionate and fraudulent prohibited attempt to illegally collect a disputed debt.   Not only did XXXX  multiple counsel violate required disclosure notices by falsely represented that there were no related cases such as the XXXX XXXX XXXX XXXX cases filed XXXX  months prior in XXXX XXXX to successfully forum shop a more sympathetic state judge to induce the Clerk to select a random judge but XXXX  counsel at Aldridge and XXXX intentionally violated in both filings XXXX XXXX XXXX XXXX XXXX XXXX XXXX  [Minimization of the Filing of Sensitive Information] by filing XXXX sensitive and explicitly forbidden XXXX  credit card numbers of XXXX XXXX XXXX XXXX in violation of Rule 2.425(a)(3)( C ) which limits format and explicitly prohibits: (3) No portion of any credit card account number.  Not only did XXXX  file prohibited lawsuits XXXX XXXX XXXX XXXX XXXX XXXX XXXX months but XXXX  counsel violated the sensitive data prohibitions mandatting sanctions and RICO charges to boot as counsel knew it purposely violated its obligations yet did so to extort funds from XXXX.  Florida Statutes (FS) 682.03(1)(a) states if the refusing party does not appear or does not oppose the motion, the court shall order the parties to arbitrate so the state court judges can never have jurisdiction as XXXX  had XXXX XXXX XXXX XXXX XXXX XXXX Answered by XXXX  with Affirmative Defenses and there is nothing to compel as cases are under the exclusive jurisdiction of the XXXX  pursuant to the arbitration provisions.  FS 682.03(6) AUTOMATICALLY STAYED the XXXX  state court cases as If a party makes a motion to the court to order arbitration, the court on just terms shall stay any judicial proceedings that involves a claim alleged to be subject to the arbitration until the court renders a final decision under this section  The XXXX  cases are actively pending in XXXX XXXX so the state court is powerless to act except to sanction XXXX  attorneys and refer their misconduct to the XXXX  Bar.  The XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, demonstrating an identical case where the agreement clearly and unmistakably evidences the parties intent to empower an arbitrator, rather than a court, to resolve questions of Arbitrability mandating binding private arbitration and automatically staying motions until the court renders a final decision regarding arbitration.  Identically, the XXXX XXXX XXXX Order by XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX GRANTING Defendants Motion to Compel Arbitration with the case STAYED.  XXXX XXXX wrote using the same argument that XXXX  presents regarding the AIRBNB case: 
As the Defendants argue, by incorporating XXXX XXXX XXXX rules into their agreement, parties clearly and unmistakably evince an intent to delegate questions of XXXX  because the XXXX  rules empower the XXXX  to rule on his or her own jurisdiction, including any objections with respect to the existence, scope of validity of the arbitration agreement. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  The XXXX  clauses incorporation of the XXXX  rules is clear and unmistakable evidence that Cartesian and Construct Software Technologies agree to arbitrate the question of whether Cartesians claims are arbitrable.

Therefore, since XXXX  filed XXXX  with XXXX  in XXXX XXXX XXXX XXXX XXXX XXXX there can be no valid state court case to compel arbitration so state court actions are VOID and XXXX  is responsible for its frivolous filing, which includes RICO and extortionate fraudulent demands known to be improper. 
XXXX  racketeering activity is widespread and continuous and gets worse day to day in face of the XXXX  CEASE and DESIST Notices and XXXX actively pending XXXX XXXX  cases. How much of a fee or commission does Aldrige, XXXX XXXX XXXX XXXX XXXX expect to be paid by XXXX  to justify continuation of cases and jointly conspiring to file prohibited actions???  Is it worth risking losing jobs, reputations, licenses to practice law or losing clients such as XXXX?  What will XXXX Executive Vice-PresidentXXXX XXXX XXXX XXXX XXXX do to prevent escalation to the CFPB for enforcement and sanctions in the millions?  I merely present the undisputed facts asking others to answer the questions.  Of course, the dispute with XXXX  will never end as I projected long ago until the XXXX XXXX does the right thing.  Court rules obligate filing attorneys to ethically comply with rules, including barring explicitly prohibited sensitive data as the Clerk is not responsible to catch violations and there is no defense for submitting prohibited barred pleadings hoping to rely on the Clerk to catch, BY CHANCE, violations.  XXXX  and its attorneys must be punished for their relentless criminal conduct. At this point, before making further points, it is appropriate to discuss some of the available damages.  In XXXX XXXX XXXX XXXX XXXX  a jury verdict was upheld where a jury awarded Medley XXXX in statutory damages and XXXX in punitive damages (225 times statutory damages) for violations of Florida Consumer Collection Practices Act (FCCPA), including Fla. Stat. Section 559.72(18), due to communications to collect a debt after being notified of attorney representation.  A simple comparison of the Medley case to XXXX  reprehensible relentless criminal conduct should result in an arbitration award of XXXX+ by any XXXX XXXX.  While XXXX seeks only XXXX to induce a settlement, a small fraction of available damages, XXXX  reserves the right to increase damages claimed and, regardless, an XXXX  has the Inherent Power to award more than the XXXX maximum claimed in the interest of justice if deemed appropriate. At this point, even if the criminal conduct does not constitute enough activity to justify RICO criminal conduct, it becomes irrelevant when determining the appropriate damage to award based on the relentless egregious conduct by XXXX  and its attorneys. At this point, it has become obvious that XXXX  will continue to escalate matters with frivolous and criminal conduct until stopped by an XXXX  with a huge award against XXXX