Bartlett v. Portfolio Recovery Associates, LLC

Rainford G. Bartlett v. Portfolio Recovery Associates, LLC, No. 64, September Term 2013, and James Townsend v. Midland Funding, LLC, No. 76, September Term 2013, Opinion by Greene, J. SMALL CLAIM ACTIONS – JUDGMENT ON AFFIDAVIT – ASSIGNED CONSUMER DEBT CASES In pursuing a judgment on affidavit, involving a small or large claim, a debt buyer plaintiff must produce certain documents, as contemplated by Maryland Rule 3-306(d), sufficient to pass muster under the business records exception. Once a small claim action is contested and proceeds to a trial on the merits, the parties are not…