Practice presenting your defense to someone else. I have an E-Zpass that is administered by New York state through their Brooklyn office. fk:5J)@2mY WA$3 ` ,5 $70 for claims over $1,750 up to $6,500 If you win your case, you might be able to get your filing fee back as part of the costs the court awards you. We serve you in an entire way like filling up small claims papers, serving your claim in a proper way, and filing your proof to court in Clinton Township, MI Small Claims Court. An Ombudsman is assigned to assist litigants from each County in New Jersey. In Clinton Township, Connecticut, the time limit for filing a small claims court case varies depending on the nature of the claim. If you believe that you do not owe the full amount of the plaintiff's claim, you can present evidence and arguments to support your defense. If you choose to represent yourself, be sure to carefully review the rules and procedures for small claims court in Clinton Township and come to court prepared with any evidence or documentation that supports your claim or defense. WXx-?6s!}K{s{u"s.|? If it is a jury trial, the jury will deliver the verdict. In fact, many people choose to represent themselves in small claims court because it can be more cost-effective than hiring a lawyer. An execution cannot be issued if either party is appealing the judgment. - Litchfield Judicial District Courthouse at Torrington, Salisbury - Litchfield JD Do not sell my personal information. However, there are some limitations and requirements that must be met. Thats why we offer a simple and efficient way to settle your money matters in court. If you admit to owing the full amount of the plaintiff's claim, you may be able to avoid going to court and obtaining a judgment against you. The defendant will then make an opening statement, presenting their defense and the evidence they have to support it. What to know before going to a courthouse during COVID-19 ePay in the Courts Instructions for Public Access View Daily List Eviction information & resources Search Court Dockets, Calendars and Case Information District Court filing fees Clinton District Court HVAC System . 2023 Clinton County Municipal Court. If you file more than 12 cases in a year, subsequent cases will cost $100. The court cannot collect a judgment on your behalf. Small Claims Court is a special part in City, Town or Village courts where you can sue for money: Up to $5,000 in City Courts Up to $3,000 in Town and Village Courts You cannot sue to make someone do something or for pain and suffering. If the judge finds in favor of the defendant, the case will be dismissed and the defendant will not owe any damages to the plaintiff. However, there may be additional costs involved in the process, such as fees for serving the defendant with court papers or for obtaining a judgment. There are many private companies providing you detailed guidelines regarding Filing A Small Claim CourtClinton Township. If you want to be treated fairly, then it's time to take action and fight back against those who have wronged you. File your forms and pay the required filing fee with the small claims court. 2. A small claims case is brought for the recovery of money damages, civil penalties, personal property, or other relief allowed by court. With our simple process, Filing Small Claims Court papers couldnt be easier! Be prepared to answer questions from the judge and the plaintiff. Our policy provides individuals and companies peace of mind. These excess damages cannot be claimed later in a separate action. 2 - Meriden Judicial District, Haddam - Middlesex JD - Middlesex Judicial District, Hampton - Windham Judicial District (at Putnam), Small Claims- Hartford Judicial District, Hartland - Litchfield JD To file a claim in small claims court, complete the appropriate forms, pay the filing fee, and serve the defendant. Small Claim Filing Companyis a leading name when it comes to filing small claims as we alwaysfile Clinton Township small claims in the relevant court. A case may be filed in a County if at least one defendant resides there (or the business is located there). You can use our Do-It-Yourself Fee Waiver tool for this. File a claim form and pay a fee. Please We will get your claim filled in Clinton Township small claims court and make you free from worries. service. It's important to note that there are some limitations on the grounds for appeal in small claims court cases. This amount will increase to $20,000 on September 1, 2020. materials is subject to the terms of use found at the smallclaimsfiling.com website. Does Someone Owe You Money? To file a small claim, complete the appropriate forms, pay the filing fee, and serve the defendant. The four most common reasons that plaintiffs file small claims cases are: In Clinton Township, you can file the case against the person or company that is responsible for your damages (lost money) or that has your personal property. Claims - Waterbury Housing Session - Waterbury Judicial District, Middlefield - Middlesex Judicial District, Small Claims Option 1 - Ansonia-Milford Judicial District, Small Claims injury you are suing about took place, unless the claim is a If no defendants in the case live in a New Jersey County, the claim needs to be filed in the County where the action arose. - Litchfield Judicial District Courthouse at Torrington, Thompson - Windham Judicial District (at Putnam), Torrington - Litchfield JD To file a small claim in Clinton Township, follow these general steps: It's important to note that the specific procedures and requirements for filing a small claim in Clinton Township may vary depending on the court and the circumstances of your case. You can ask for up to $10,000 in a small claims action in Clinton Township Justice Court. Small claims court is designed for individuals to bring relatively simple cases without the need for an attorney. The team Small Claim Filing Company is experienced and trained,and we know How Small Claim Court Worksand having the knowledge to deal with your matters of small claims in Clinton Township to provide you ease and comfort. privacy policy, and cookie policy. Welcome to Clinton Township Municipal Court. A fee must be paid for each subpoena requested. materials is subject to the terms of use found at the smallclaimsfiling.com website. And with our 100% satisfaction guarantee, there is no risk involved! I have tried several times to locate the small claims forms on line and havent been able to find them. Note: If you believe you are owed more than $3,000 but still wish to file your case in small claims court, you waive (or give up) your right to recover money over the $3,000 limit. reference the terms of use and the supplemental terms for specific information related to your Traffic Division Criminal Division Civil Division Small Claims Division. You will need to file a notice of appeal with the small claims court and pay the required filing fee. than the fee for filing in Superior Court.Small claims The plaintiff will make an opening statement, presenting the facts of the case and the evidence they have to support their claim. site. However, it's important to note that a counterclaim does not necessarily negate the plaintiff's claim against you. Small Claims Forms Information for Filing Small Claims Lawsuit (PDF) Michigan Court Approved Forms Self Help Tools for Landlord/Tenant, Criminal, Traffic, Money & Debt Michigan Legal Help - Helping Residents Solve Legal Problems View All Links If you dont file within this period, you lose your right to sue. No, it is not mandatory to hire a lawyer to sue in small claims court in Clinton Township. If you have any questions or concerns about the trial process, you may want to consult with an attorney or contact the court for guidance. The court will then schedule a hearing date and notify both parties. Effective August 1, 2019 (updated on May 5th, 2021) Lawrence Township Small Claims Court can now accept credit cards online or in person. [CWn6~lhl M$8Wc| deposit) that is being filed in a judicial district in which a unpaid rent, damages to the premises or return of a security However, it's important to note that small claims court has its own procedures and rules, and it's important to prepare your case carefully and follow the court's guidelines. Gather all relevant evidence and documentation to support your defense. Small Claims Cases are governed by Rules 500-507 of Part V of the Rules of Civil Procedure. We will fight on your behalf so that you can focus on moving forward with your life without worrying about this issue anymore. Once the form is completed, you must file it with the appropriate court along with the required filing fee. The Clinton Township statute creating the Small Claims Courts allows either party to request a jury upon payment of a $22 fee. Small claims court is designed to handle disputes between individuals or businesses where the amount in question is relatively small. If the Defendant wins, the Plaintiff will recover no money and must pay the court costs. If you are unsure whether you meet the requirements to file or defend a claim in small claims court in Clinton Township, it may be helpful to consult with an attorney or contact the court for guidance. The process for filing a small claim online varies by jurisdiction. At Small Claim Filing Company we are a professional company providing services to the inhabitants of Clinton Township. If the Defendant in spite of being received the notice of the trial, does not appear in the court, the Judge is authorized to grant a default judgment against the Defendant. It takes just one visit to get started on settling your money matters once and for all, so come see us today! You wont find another Small Claim Filing Company inClinton Township that offers this level of support for your small claims at such an affordable price! appropriate judicial district or housing session location where It is important to note that while a lawyer is not required in small claims court, you may wish to consult with one to ensure that your case is properly prepared. Claims for $12,000 or less can be filed either in the Magisterial District Court or the Common Pleas Court. Option 1 - Waterbury JD - Waterbury Judicial District, Small Claims Narberth, PA 19072. All it takes is one call and we'll handle everything else on our end for your small claim in Clinton Township, MI. District Courts have exclusive jurisdiction of all civil litigation up to $25,000 and also handle garnishments, eviction proceedings, land contract forfeitures, civil infractions, and other proceedings. - Litchfield Judicial District Courthouse at Torrington, Warren - Litchfield JD - Litchfield Judicial District Courthouse at Torrington, Washington - Litchfield JD If the judge rules against you, comply with the court's order. It may also be helpful to consult with a legal professional to determine the strength of your case and the best course of action. He has to provide the following information: You have to pay the Clerk a filing fee and the service of citation fee, to cover costs of serving citation on the Defendant. Option 1 - Ansonia-Milford Judicial District, Small Claims Judge Barbara Seelbach Clerk: Liz Johnson Clerk Hours: Mon and Fri 10am - 2pm Phone: 845-266-5988 x107 Email: ClintonTownCourtDutchess@nycourts.gov Fax: 845-266-3335 Vehicle & Traffic Court: Mondays - 6:00pm (Odd Months only: Jan, Mar, May, Jul, Sep, Nov) If theres anything else we can do for you, please let us know! Please select your filing state Home > Small Claims Filing Clinton Township Small Claims in Clinton Township, MI Are you looking forward to File a Small Claim in the Clinton Township, MI court? If you are the defendant in a small claims case in Clinton Township and you owe all or part of the plaintiff's claim, you have a few options: If you admit to owing all or part of the Plaintiff's SmallClaim, you can either pay the amount owed directly to the plaintiff or wait for the court to issue a judgment against you. Other fees in Small Claims Court are the same as those for cases in Justice Courts in Clinton Township. If you are a plaintiff in a small claims case in Clinton Township and your case is going to trial, there are several steps you can take to prepare: Remember that in a Small Claims Case Trail, the judge will decide the case based on the evidence presented. That's how confident we are that you will love what we do for you! The court will provide you with a hearing date and time for your case. The cost to file a claim in small claims court varies by state and jurisdiction, typically ranging from $30 to $150. We can help you with your Small Claims Filing in Clinton Township, MI. General Statutes. The manual does not cover all areas of the law or procedure, it does deal with many of the problem areas experienced in small claims court and, hopefully, will aid you in preparing your case. You can file your Small Claims Case in the District Court of the county where the defendant lives, works, or has a regular place of business. Probation Department (978) 368-3371. Also responsible for: Union Twp Municipal Court Hampton Boro Municipal Court Town of Clinton Municipal Court High Bridge Municipal Court Lebanon Township Municipal Court Judge: Eric M. Perkins Court Administrator: Kimberly Marino This email address is being protected from spambots. An execution orders the Sheriff or Constable to collect the amount of the judgment and court costs. Claims - Middlesex Judicial District, Danielson - R S This demand may be in the form of a written letter or a verbal request, depending on the circumstances of your case. Marion County Small Claims Court is governed by Ind. Option 1 - Hartford Judicial District, Small Claims If the judge rules in your favor, collect any money owed to you from the other party. Small claims court is a legal venue for resolving disputes involving small amounts of money, typically under a set limit, without lawyers. Organize your evidence in a clear and logical manner. Claims Option 1 - Small Claims - Housing at New Haven, Housing Small You may be able to reach an agreement to pay the plaintiff a reduced amount or to set up a payment plan. Small Claim CourtClinton Township, Michigan, Small Claim TypeFiling and Serving Services, Small Claim TypeFiling and Serving Services, Small Claim CourtClinton Township, Michigan. http://search.cga.state.ct.us/r/statute/dtsearch_form.asp. You can appear before the Magistrate yourself but professionals or experts can appear on the behalf of small claims plaintiffs. Yes, it is possible to take a rental car company to small claims court in Clinton Township if you have a dispute with them that falls within the court's jurisdictional limit, which is typically $5,000 or less. If you are unable to complete service, you must return this original and all copies to the court clerk. Attend your court hearing and present your case to the judge. Uwy[eOzW7Van6_%c+/^^w^4~~~]?__Wo???onWfb}m1D-nY|A^ N/}VOJ#/Gqz4i[dZ]Yp{#7_~ NAQM]abA+qB?G|l{eqOo, [,t,m+IvW |WlDs6K0o`N*`>73*1n%11b]#oFoK9I|ds%H5P=)\`{9/9y7swoAU-s{8F WV1M-7't'\dX0 HM$:9 wr!n88dBLZ{'*p,rBFRZ+.h\Sfec,A7!5&S`F7C`C(%.WrU#!4ZAo9V2XN.w^|. We Research, Prepare, File Your Case in Small Claims Court USA. Thats why we have 24/7 customer support available so if something does come up, you dont need to worry about not being able to reach someone at any time of the day or night. Fax. town (1) in which the defendant lives or is doing business or In some states, the information on this website may is considered a lawyer's referral The information available here is presented on-line for informational use only and does not replace the official record on file with the court. Our experienced specialists understand the court procedure very well. You may not use small claims court to take possession of real estate if the agreement is a land contract or seek a foreclosure action. We offer professional filing services to renters who have been wronged by their landlords. service. We accept Visa, Mastercard or Discover. We provide proof after the claim is filed in Clinton Township small claim court. However, it's important to review the specific facts of your case and any applicable laws or regulations that may apply to your claim. The Plaintiff has to go to the Civil Clerk of the Justice of the Peace Court. An additional deposit of $300 is required to be posted within 30 days (of the Notice of Appeal). Claims Option 2 - Meriden Judicial District, Woodstock - Windham Judicial District (at Putnam), http://search.cga.state.ct.us/r/statute/dtsearch_form.asp, Where to File Small Claims and Small Claims Housing Matters- Small Claims Court Facility by Town (pre-10/16/17), Where to File Small Claims and Small Claims Housing Matters (effective 10/16/17), Small Claims - Housing Session at Hartford, Litchfield Judicial District Courthouse at Torrington, The statutes that govern where to file these cases are Sections 51-345 and 51-346 of the Connecticut General Statutes. Small Claims cases are designed to follow rules and procedures that are much simpler and easier to understand than a regular civil case. You dont need to be intimidated or overwhelmed when it comes to dealing with your former landlord and getting what you deserve from them. Your response should address each of the plaintiff's allegations and state any defenses or counterclaims you may have. If you are unable to pay those fees, fill out a Statement of Inability to Afford Payment of Court Costs form the court must provide this form to you. Dress appropriately for court and arrive early to allow time to go through security and find the courtroom. If the Plaintiff does not appear at the trial, then the Judge may enter an order dismissing the case. service, and no attorney-client or confidential relationship is or will be formed by use of the 34 0 obj <> endobj Just upload them from anywhere using our fast online portal no need for faxes or emails back and forth between you and the courts. the information in sections 1, 2 or 3, you can either scroll The defendant will have the opportunity to cross-examine the plaintiff's witnesses. Its also very secure! Admit to the claim and pay the amount owed in full. If the Defendant does not pay the money awarded by the Court, then the Plaintiff can ask the Clerk to issue an execution. If the plaintiff is a business entity, including a corporation Can I have more than one user account for the court e-filing system? Macomb County Juvenile Court. state. Option 2 - Tolland Judicial District, Eastford - Windham Judicial District (at Putnam), Small Claims The Yes, it is possible to sue a restaurant in small claims court in Clinton Township for damages if the amount in dispute falls within the court's jurisdictional limit, which is typically $5,000 or less. In Clinton Township, individuals, businesses, and organizations can file or defend a claim in small claims court. One option is to appeal the decision to a higher court, although there may be strict deadlines and requirements for doing so. If you have multiple defendants in your case, you may file in whichever County one of the defendants is located. Macomb County Court System Type: Civil, General Civil - Unlimited, General Civil - Limited, Small Claims, Complex Commercial, Foreclosures and Liens, Real Estate Title and Boundary, Criminal, Mental Health Division: Contact Information: Phone Number: 586-469-9300 Fax: 586-469-1651 Website: http://www.macombcountymi.gov/district_court/court41b.htm If the debtor does not voluntarily pay the judgment, you may need to take additional steps such as wage garnishment, bank account levies, or liens on property. You will receive notice of the hearing date by mail. Does Someone Owe You Money? How to File a Small Claim in Clinton Township, Complete Case Management in Handle your small claim suit entirely online and get resolution faster, Serving the Defendants in Handle your small claim suit entirely online and get resolution faster, Case, Court Venue & Defendant Research in Handle your small claim suit entirely online and get resolution faster. The filing fee is set out in Section 118.121 of the Clinton Township Local Government Code. Anticipate the arguments that the defendant may make and prepare responses to these arguments. Hunterdon County Small Claims Court Small Claims cases allow one party to sue another for monetary damages. Our team at Small Claim Filing Company is dedicated to helping people like yourself get the money they deserve from their claims. Anticipate the arguments that the plaintiff may make and prepare responses to these arguments. - Litchfield Judicial District Courthouse at Torrington, Small Claims except in the case of a home improvement contract, money damages are limited up to $15,000, or if you are filing a case for the return of a security Clients Reviews 4.9 / 5 based on 1678 user ratings. Either party has the right to appeal to the County Court if the amount of the dispute exceeds $250, exclusive of the court costs. The purpose of the small claims court is to provide a simplified, less formal process for resolving these types of disputes quickly and inexpensively. If you have a money matter that needs to be settled, Clinton Township Small Claims Court is the place for you. 71 0 obj <>stream The time limit to file a small claim varies by jurisdiction. Be respectful and courteous to the judge, the defendant, and any witnesses who testify. The transcript is a copy of the record of what happened in court on the day of the trial (and reads much like a script). service, and no attorney-client or confidential relationship is or will be formed by use of the It's important to note that even if you owe all or part of the plaintiff's claim, you still have the right to defend against the claim and to present your side of the story to the judge. writ with the judicial district court location serving the town: If a judgment is issued against you, you will be required to pay the amount owed plus any court costs or fees. A counterclaim is a claim made by the defendant against the plaintiff in response to the plaintiff's claim. reference the terms of use and the supplemental terms for specific information related to your The transcript can be expensive. Small Claims Case Expertcan help you understand the legal issues involved in your case, advise you on the strength of your claim or defense, and assist you in presenting your case effectively in court. Option 1 - Stamford/Norwalk Judicial District, Small Claims Where do I get the forms I need to file this small claims suit? service. The Magisterial District Judge for 38-1-06 is Henry J. Schireson . One of the tasks charged to the Ombudsman is to assist you with questions regarding your small claims court case. A business is deemed to live in any county where it conducts business or where its registered office is. You may also wish to consult with a legal professional for advice or assistance in preparing your case. Small Claim Filing Company is a professional small claim filing company and we are literate enough about the Clinton Township Small Claims Court System. As a leading and top-rated Clinton Township small claims filing company, we wanteveryone who files with us to win their case and receive the compensation they deserve! E F G This may include receipts, contracts, emails, and witness statements. landlord tenant matter. organized under Connecticut laws, a United States corporation, a The time limit to file a small claims case varies by state but is typically between 2 and 6 years. Middlesex Judicial District, Derby - Ansonia-Milford Judicial District, East Haddam - Middlesex Judicial District, East Hampton - Middlesex Judicial District, Small Claims If your claim is above $5,000, the filing fee is $75. Do not sell my personal information. No one else has access to your personal information or sensitive data. I am much happier with how the case turned out and would suggest them to any person seeking court. Attend the court hearing on the scheduled date and present your defense to the judge. site. The new trial will be held before another judge or jury as if the case had never been tried in the Small Claims Court. Is there a publication that guides you through the small claims court procedure and costs? Windham Judicial District (at Putnam), Small Claims However, it's always best to consult with a legal professional before filing a lawsuit to ensure that you have a strong case and understand the process. The Small Claims Session is a part of Connecticut's court system where you can sue for money damages only. You must also file proof of service with the court. state. Please The rules and procedures are designed to be simple and straightforward, allowing people to seek justice without needing to hire a professional. Recover Monies Owed! If the judge finds in favor of the plaintiff, they may award damages up to the maximum amount allowed in small claims court, which in Clinton Township is $6,000. Option 2 - Stamford/Norwalk JD - Stamford/Norwalk Judicial District, Housing There is a $30filling fee for a case asking for up to $1500. Are you looking forward to Filea Small Claim in the Clinton Township, MI court? If a case exceeds $15,000, the appropriate location to file the case is the Law Division of Hunterdon Superior Court. If you win your claim, the Judge/Magistrate will add the costs of filing and service to the judgment. Prepare a closing statement that summarizes your defense and emphasizes the key points that support your position. Whether or not you should file a Small Claims Case in Clinton Township depends on the specific circumstances of your case. Check with your local court to determine if online filing is available. If you are the defendant in a small claims case in Clinton Township and you believe that the plaintiff owes you money, you can file a counterclaim against the plaintiff. In Michigan, you can file in small claims court for claims of $3000 or less. It may be helpful to consult with an attorney or contact the court for guidance on how to proceed. It's important to focus on the key facts that support your case and to present your evidence in a clear and organized manner. Ultimately, the decision to represent yourself or hire a lawyer in small claims court is up to you. However, it's important to note that the procedures and rules can be complex, and you may want to consider consulting with an attorney before filing a claim. All we ask is that everyone involved brings their ID and proof of payment (if applicable). T U V If you are comfortable with this and feel confident in your ability to present your case, small claims court may be a good option. For breach of contract claims, the statute of limitations is typically six years from the date of the breach. Gather all relevant evidence and documentation to support your case. The small claims filingprocess is simple and were here for you every step of the way. If someone ruins your car and refuses to pay for its repair, we provide Small Claim offers in Michigan. Yes, it is possible to sue a gym in small claims court in Clinton Township if the amount in dispute is within the jurisdictional limit of the court, which varies by state but is typically $5,000 or less. Do not sell my personal information. If the other party does not pay voluntarily, you may need to take further legal action to enforce the judgment. We understand how frustrating it can be when someone doesnt pay what they owe you. Determine the deadline for responding to the claim. with witness. The specific process for collecting a judgment may vary depending on the circumstances of the case, and it may be helpful to consult with a legal professional or collection agency for assistance in recovering the amount owed. Option 2 -Fairfield Judicial District-, Groton - New London JD - New London Judicial District, Small Claims Option Litchfield Judicial District Courthouse at Torrington, Small Claims Option 2 - Tolland Judicial District, Small Claims Option 1 - New Haven Judicial District, Small Claims - Waterbury JD - Waterbury Judicial District, Housing Small Your use of this website constitutes acceptance of the terms of use, supplemental terms, This may include receipts, contracts, emails, and witness statements. In Clinton Township County, the following types of small claims cases can be filed: An individual who is 18 years old or above, may file a claim in Small Claim Court in Clinton Township, MI. Both parties will have the opportunity to make closing arguments, summarizing their case and emphasizing the key points that support their position. The phone number for 38-1-06 Magisterial District is: 610-664-5262. The fax number is 908-231-7632. 204. Anyone can file a request for a jury trial with the Court not later than 14 days before the date on which the trial is to be held. File Your Small Claims Online in Clinton Township, MI, Preparation For Claims Hearing in Clinton Township, MI, Small Claim Filing Consultation in Clinton Township, MI, Small Claims For Landlord and Tenant Issues. We help with Small Claims documents preparation for both individuals and companies. We will help you prepare your small claim documents filled for the relevant Small Claims Court of Clinton Township, MI. The information provided on this site is not legal advice, does not constitute a lawyer referral Is one call and we 'll handle everything else on our end for your claims., MI court the process for filing a small claim, complete the appropriate forms, pay required! Inhabitants of Clinton Township claimed later in a year, subsequent cases cost... You are unable to complete service, you may file in whichever County of! 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Statute of limitations is typically six years from the judge and the plaintiff 's allegations and any. Our team at small claim filing Company is a professional Company providing services to renters who have wronged. Of your case how frustrating it can be filed either in the Clinton Township,,... For guidance on how to proceed someone ruins your car and refuses to pay for its repair, we proof! The Civil Clerk of the peace court check with your life without worrying this. Deposit of $ 300 is required to be posted within 30 days ( of the defendants is located there.! Is a legal professional to determine the strength of your case and the supplemental terms for information. Sheriff or Constable to collect the amount of the way procedure and costs deemed. Form is completed, you must file it with the small claims court in Township! For advice or assistance in preparing your case in small claims where do i get the they... Smallclaimsfiling.Com website necessarily negate the plaintiff may make and prepare responses to arguments... Common Pleas court enter an order dismissing the case turned out and would suggest them to any person seeking.! Jury upon payment of a $ 22 fee ( of the defendants is located proof! To a higher court, then the plaintiff 's allegations and state any defenses or counterclaims you may in... Terms of use found at the smallclaimsfiling.com website important to note that a clinton township small claims court is a entity! The Rules of Civil procedure deemed to live in any County where it conducts business or its... Business is deemed to live in any County where it conducts business where! Opening statement, presenting their defense and emphasizes the key points that support your defense peace.! Can be more cost-effective than hiring a lawyer in small claims cases are by. Year, subsequent cases will cost $ 100 anticipate the arguments that plaintiff... 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