S_AZ PASS-10 — Arizona consumer money-debt merits, ownership, assignment, and account proof
Research date: October 27, 2026. October 22 is the project baseline, not the verification date for this pass. The sources identified below were freshly accessed during this pass. Exact opening times for individual sources were not logged and are UNKNOWN.
The central finding is that Arizona’s proof requirements depend on the cause of action, the evidence offered, and the stage of the case. Contract liability, ownership of the particular obligation, admissibility of records, and correctness of the amount are separate questions. A document can satisfy one question while leaving the others unresolved.
Several distinctions materially affect this component:
- Arizona’s credit-card statute permits acceptance through specified conduct, including authorized use; a wet-ink signature is not universally required. The applicable agreement and disputed terms still matter.
- The statutory final-statement route concerns the amount in an uncontested credit-card action. A contested action requires the court to weigh the evidence.
- Assignment evidence must identify the obligation transferred and support the asserted transfer. Neither a portfolio-sale label nor a branded statement necessarily connects the particular account to the plaintiff.
- Business-record authentication, a hearsay exception, and sufficient proof of liability are distinct. A qualified witness need not have personally created every record, but possession of records and a conclusory assurance of reliability are insufficient substitutes for the required foundation.
- Arizona amended its summary-evidence rules effective January 1, 2025. An admissible Rule 1006 summary is different from a Rule 107 illustrative aid.
- Eldred is a memorandum decision, not published precedent. Its discussion of silence following a collection notice must be considered alongside the federal statutory prohibition against construing failure to dispute under §1692g as an admission of liability. The federal provisions were recovered in the official 2024 Code edition; later federal currentness remains expressly held.
These findings are supported by claims C003–C006, C023–C024, C030–C045, C059, C071, and C076–C079 below. Acceptance of credit card agreement+5
Reading conventions and limits
In the tables, S001 means S_AZ-P10-S001, and C001 means S_AZ-P10-C001. Full identifiers appear in the source and claim registers.
- D: direct statutory or rule text.
- H: published judicial holding.
- M: memorandum-decision reasoning, subject to citation restrictions.
- I: inference from identified authority.
- X: conditional fictional application or arithmetic.
- G: evidence or currentness gap.
“Supported” means supported within the identified text, version, and factual predicates. It does not mean that any actual debt, plaintiff, record, charge, or lawsuit has been validated.
1. Causes of action and the elements that need proof
Cause-of-action and element matrix
| Theory |
What the claimant must establish |
Material evidence and distinctions |
Limits and claim references |
| Express contract, including a written account agreement |
Existence of a contract, breach, and resulting damages. |
Identify the parties, applicable agreement, obligation breached, and terms necessary to calculate the requested recovery. An agreement from a different date or product needs a demonstrated connection to the account. |
C002–C008, C059. A particular signature format is not universally required. Applicable writing requirements and choice of law remain transaction-specific. |
| Oral or implied contract |
A legally cognizable agreement, breach, and damages; the absence of a signed document does not itself supply or negate those elements. |
Conduct, communications, performance, and other admissible evidence may matter. ChartOne involved an implied-contract claim, but it did not eliminate proof of damages. |
C002, C009–C011. This pass does not decide statute-of-frauds, guaranty, or other special writing requirements for an unidentified transaction. |
| Open account |
Correctness of the account and its individual items. |
Transactions, authorized charges, credits, and a supported opening balance. A running balance is not self-proving merely because it appears in an accounting system. |
C012–C013. Holt also shows why missing older invoices are not invariably fatal: on its facts, properly applied payments extinguished the unsupported opening debit. |
| Account stated |
An actual agreement, express or inferable from circumstances, fixing an agreed balance. |
Receipt, finality, the parties’ relationship, objections, communications, and conduct matter. A statement or silence does not universally establish assent. |
C014–C015, C071. Ongoing monthly billing and a final adjustment are materially different postures. |
| Unjust enrichment |
Enrichment, corresponding impoverishment, a connection between them, absence of justification, and absence of an available legal remedy. |
Identify the actual benefit and why retention is unjust. A contract governing the parties’ relationship limits resort to unjust enrichment. A separate contract with a third party does not automatically resolve that question. |
C016–C018. Markham supplies a current statement of the elements in a construction dispute; its sector-specific facts are not imported into consumer accounts. |
The plaintiff’s proof burden does not become the defendant’s burden to disprove the debt merely because the plaintiff files for summary judgment. Allen reversed a creditor’s summary judgment because the creditor’s own showing was inadequate; it did not adjudicate that the debt could never be proved on remand. C058–C061. cases.justia.com+5
Identity, assignment, and account-linkage evidence matrix
These are evidence questions, not a universal list of mandatory document names.
| Proposition needing proof |
Potentially responsive evidence |
What remains unresolved without the linkage |
Claims |
| The defendant is the contracting cardholder or other obligor |
Applicable agreement, attributable electronic acceptance, authorized-use evidence, admissions, transaction evidence |
A similar name, mailing address, or account label does not alone resolve identity or authority. |
C003–C004, C010, C072 |
| The original creditor held the asserted right |
Origination records, applicable agreement, issuer/account records |
A statement brand may differ from the legal issuer or owner. |
C002–C008, C019 |
| A first assignment transferred this obligation |
Transfer instrument, identified account schedule or other account-level evidence, competent explanatory evidence |
A generic sale of unspecified accounts may leave the subject matter unidentified. |
C023–C024 |
| A second assignment transferred the same obligation |
Each transfer’s scope, dates, account identifiers, exclusions, and evidence connecting renamed or renumbered accounts |
The second buyer cannot fill a missing first link merely by repeating its own balance field. |
C024–C025 |
| The offered schedule belongs to the offered sale |
Cross-references, file identifiers, transmission or custody evidence, qualified testimony or certification |
An unattached spreadsheet with no demonstrated relationship to the sale remains a linkage problem. |
C024, C030–C043 |
| Redacted material still identifies the relevant obligation |
Retained account-level identifiers and competent explanation; additional portions where fairness requires |
Redaction is neither automatically fatal nor automatically sufficient. Actual completeness and confidentiality questions remain case-specific. |
C024, C046 |
| A servicer or agent may act for the owner |
Agency agreement, scope of authority, applicable representative-party rule |
Servicing authority and ownership are different propositions. A license label does not answer either. |
C019, C022, C028 |
| The plaintiff’s interest changed during litigation |
Transfer date, existing party status, substitution or joinder record where applicable |
Rule 25(c) permits continuation by the original party in specified circumstances; sale during litigation does not invariably require immediate dismissal or substitution. |
C020–C021 |
| Assignment left defenses intact |
Payment, release, setoff, and notice-of-assignment facts; applicable statutory exceptions |
The transfer date and the date of notice are not interchangeable under §44-144. |
C026–C027, C068 |
| Portfolio purchase consideration was not a consumer payment |
Sale consideration records distinguished from consumer receipts and contractual credits |
A discount does not, by arithmetic alone, establish a credit to the consumer’s account. |
C029, C084 |
Lesnick found the offered assignment insufficient because the purported transfer did not adequately identify the creditor relationship and obligation, and the evidentiary gap was not supplied by other proof. The Arizona Supreme Court quoted its identification principle again in Pointe 16 in 2025. Neither opinion establishes that every consumer debt must be proved through one prescribed form of bill of sale. C023–C025. law.justia.com+1
2. Complete source and access register
Source-status conventions
All accesses below occurred October 27, 2026.
- Fresh body: the identified substantive portions were read.
- Fresh partial: identified portions were read; the entire document or amendment chain was not.
- Index: navigation, currency, or discovery material; not a substitute for operative text.
- Reproduction: the court-authored opinion was read on a disclosed nonofficial host.
- Failed/discovery: no operative body was obtained through the stated routes.
For HTML sources, PDF page/index is not applicable. For PDFs, printed pages and zero-based PDF indices are supplied where established. A page number not established from the read material is not inferred.
2.1 Statutes and enactments
| Source ID |
Issuer; document; direct literal HTTPS URL |
Actual read scope, version, effect, and limitations |
| S_AZ-P10-S001 |
Arizona Legislature, A.R.S. Title 44. Representative operative URL: https://www.azleg.gov/ars/44/07801.htm. Complete section-access map follows. |
Fresh bodies: the 19 sections listed below. Current legislative compilation, subject to S007’s currency convention. Credit-card chapter compared with S004. UETA’s original enactment body was not recovered; S041 preserves that gap. Sections within this compilation are not independent corroborating documents. |
| S_AZ-P10-S002 |
Arizona Legislature, A.R.S. §22-216. https://www.azleg.gov/ars/22/00216.htm |
Fresh body: entire section, especially A(2)–(3), (5)–(11). Current clean text requires specified allegations in a written, signed pleading. Compared with S005; no universal affidavit-verification requirement inferred. |
| S_AZ-P10-S003 |
Arizona Legislature, A.R.S. §1-244. https://www.azleg.gov/ars/1/00244.htm |
Fresh body: entire provision. General statutory nonretroactivity text. This alone does not resolve whether a particular evidentiary or procedural change applies to a pending case. |
| S_AZ-P10-S004 |
Arizona Legislature, Laws 2012, ch. 318, HB2664. https://www.azleg.gov/legtext/50leg/2r/laws/0318.htm |
Fresh body: §1 adding §§44-7801–7806 and approval/filing notation. Approved May 9, 2012; filed May 10, 2012. No special effective or retroactive clause found in the act read. General effective date supplied by S006. |
| S_AZ-P10-S005 |
Arizona Legislature, Laws 2013, ch. 212, HB2459. https://www.azleg.gov/legtext/51leg/1r/laws/0212.htm; PDF: https://www.azleg.gov/legtext/51leg/1r/laws/0212.pdf |
Fresh partial: HTML §22 amending §22-216, §64, approval/filing notation; PDF cover and location of §22. Approved/filed June 19, 2013; effective after December 31, 2013. HTML extraction interleaves deleted and added words; the clean current section in S002 was also read. |
| S_AZ-P10-S006 |
Arizona Legislature, General Effective Dates. https://www.azleg.gov/general-effective-dates/ |
Fresh official calendar: 2012, Fiftieth Legislature, Second Regular Session: August 2, 2012. Calendar support for S004, not an independent amendment to it. |
| S_AZ-P10-S007 |
Arizona Legislature, compilation/currency notice. https://www.azleg.gov/arstitle/ |
Fresh notice: compilation identifies the 57th Legislature, Second Regular Session, 2026, and explains its January-following-session convention and drafting-use limitation. A displayed compilation date is not itself the effective date of every provision. |
S001 section-access map — one compilation, 19 fresh section bodies
| Access ID |
Exact section and material portion |
Literal URL |
| S001/A01 |
§44-7801, all definitions |
https://www.azleg.gov/ars/44/07801.htm |
| S001/A02 |
§44-7802, acceptance |
https://www.azleg.gov/ars/44/07802.htm |
| S001/A03 |
§44-7803, cardholder liability and unauthorized use |
https://www.azleg.gov/ars/44/07803.htm |
| S001/A04 |
§44-7804, uncontested/contested amount proof |
https://www.azleg.gov/ars/44/07804.htm |
| S001/A05 |
§44-7805, rate proof and cross-references |
https://www.azleg.gov/ars/44/07805.htm |
| S001/A06 |
§44-7806, preserved protections |
https://www.azleg.gov/ars/44/07806.htm |
| S001/A07 |
§44-1205, body read; C–G materially relevant to the rate/charge boundary |
https://www.azleg.gov/ars/44/01205.htm |
| S001/A08 |
§44-6002, body read as incorporated retail-account boundary |
https://www.azleg.gov/ars/44/06002.htm |
| S001/A09 |
§44-144, assignment and existing defenses |
https://www.azleg.gov/ars/44/00144.htm |
| S001/A10 |
§44-145, consumer-obligation defense rule, notice conditions, exclusions |
https://www.azleg.gov/ars/44/00145.htm |
| S001/A11 |
§44-7002, electronic-transaction definitions |
https://www.azleg.gov/ars/44/07002.htm |
| S001/A12 |
§44-7003, scope, exclusions, other substantive law |
https://www.azleg.gov/ars/44/07003.htm |
| S001/A13 |
§44-7004, prospective-application events |
https://www.azleg.gov/ars/44/07004.htm |
| S001/A14 |
§44-7005, agreement to electronic transactions |
https://www.azleg.gov/ars/44/07005.htm |
| S001/A15 |
§44-7007, legal recognition |
https://www.azleg.gov/ars/44/07007.htm |
| S001/A16 |
§44-7008, writing, retention, presentation requirements |
https://www.azleg.gov/ars/44/07008.htm |
| S001/A17 |
§44-7009, attribution and effect |
https://www.azleg.gov/ars/44/07009.htm |
| S001/A18 |
§44-7012, electronic retention and originals |
https://www.azleg.gov/ars/44/07012.htm |
| S001/A19 |
§44-7013, evidentiary treatment of electronic form |
https://www.azleg.gov/ars/44/07013.htm |
2.2 Promulgated rules and final orders
| Source ID |
Issuer; document; literal URL |
Actual body read; dates, pinpoints, and limits |
| S_AZ-P10-S008 |
Arizona Supreme Court, R-10-0035 amended evidence-restyling order. https://www.azcourts.gov/Portals/0/20/R100035Amended.pdf |
Fresh partial: order and Rules 101, 103, 408, 602, 801–802, 805, 901, 902(8), (11)–(12), 1003, 1101; relevant comments. Filed September 8, 2011; effective January 1, 2012. Later amendments below control affected clauses. Examples of known PDF indices: 103 at 4–5; 602 at 20; 801–802 at 38–40; 805 at 51; 901 at 53–55; 902 at 57–58; 1003 at 61. This is not a freshly consolidated 2026 rulebook. |
| S_AZ-P10-S009 |
Arizona Supreme Court, R-14-0002. https://www.azcourts.gov/Portals/0/20/2014%20August%20Rules/R140002.pdf |
Fresh partial: Rule 803(6) and its burden-allocation comment, printed pp. 5–6, PDF indices 4–5. Filed September 2, 2014; effective January 1, 2015. Other amended exceptions were not relied on. |
| S_AZ-P10-S010 |
Arizona Supreme Court, R-17-0003. https://www.azcourts.gov/Portals/0/20/2017%20Rules/R-17-0003.pdf |
Fresh partial: Rule 902(13)–(14) and comments, printed pp. 4–6, PDF indices 3–5. Filed August 31, 2017; effective January 1, 2018. Certification authenticates specified electronic material; it does not by itself establish a hearsay exception. |
| S_AZ-P10-S011 |
Arizona Supreme Court, R-18-0008. https://www.azcourts.gov/Portals/0/20/2018%20Aug%20Rules/R180008.pdf?ver=2018-08-28-153051-013 |
Fresh partial: Rules 1001–1004 and related original/duplicate provisions, including printed pp. 3–4, PDF indices 2–3. Filed August 28, 2018; effective January 1, 2019. Its former Rule 1006 text is superseded by S014. |
| S_AZ-P10-S012 |
Arizona Supreme Court, R-18-0003, Rule 807. https://www.azcourts.gov/Portals/0/20/2018%20Aug%20Rules/R180003.pdf?ver=2018-08-28-153050-983 |
Fresh body: order and operative Rule 807, printed p. 3, PDF index 2. Filed August 28, 2018; Arizona amendment effective January 1, 2019. The comment’s federal effective-date statement is not used; later comment amendment remains S042. |
| S_AZ-P10-S013 |
Arizona Supreme Court, R-23-0002, Rule 106. https://www.azcourts.gov/Portals/0/20/2023%20Rules/R-23-0002%20Final%20Rules%20Order.PDF?ver=_0y045CisxzkA_bME2zbcQ%3D%3D |
Fresh body: attachment, printed p. 3, PDF index 2. Filed August 24, 2023; effective January 1, 2024. Completeness provision read in Arizona’s wording. |
| S_AZ-P10-S014 |
Arizona Supreme Court, R-24-0017, Rules 107 and 1006. https://rulesforum.azcourts.gov/DesktopModules/ActiveForums/viewer.aspx?attachmentid=12715&moduleid=9811&portalid=4 |
Fresh body: order and attachments; Rule 107 printed p. 3/PDF 2; Rule 1006 printed p. 4/PDF 3. Filed August 22, 2024; effective January 1, 2025. Publicly linked final-order attachment, not a private endpoint. |
| S_AZ-P10-S015 |
Arizona Supreme Court, R-24-0020, Rule 801(d)(2). https://www.azcourts.gov/Portals/0/20/2024%20Rules/R-24-0020%20Final%20Rules%20Order.PDF?ver=YYF323xJ6EjkrDMxw6rT8g%3D%3D |
Fresh body: printed p. 3/PDF 2. Filed August 22, 2024; effective January 1, 2025. Added derived-claim/defense/liability language. |
| S_AZ-P10-S016 |
Arizona Supreme Court, R-16-0010, civil-rule restyling. https://www.azcourts.gov/Portals/0/20/2016%20Rules/R-16-0010.pdf |
Fresh partial: Rules 8(a)–(d), (i), 9(a)–(c), 10(c), 17(a), 25(c), 55(b), 56(a), (c)–(e), and relevant comments. Filed September 2, 2016; effective January 1, 2017. Known printed/PDF pairs: Rule 17 p. 67/PDF 99; 25(c) p. 80/PDF 112; 55(b) pp. 161–162/PDF 193–194; 56 pp. 163–165/PDF 195–197. Later amendments below qualify use. |
| S_AZ-P10-S017 |
Arizona Supreme Court, R-17-0009 technical amendments. https://www.azcourts.gov/Portals/0/20/2017%20Rules/17-0009.pdf |
Fresh partial: order; relevant Rule 55 material and Rule 56 comment, printed pp. 9–10/PDF 8–9. Filed August 31, 2017; principal effective date January 1, 2018; specified Rule 26 change July 1, 2018. Not relied on for excluded procedural clocks. |
| S_AZ-P10-S018 |
Arizona Supreme Court, R-17-0010 civil disclosure/discovery order. https://rulesforum.azcourts.gov/DesktopModules/ActiveForums/viewer.aspx?attachmentid=5495&moduleid=9811&portalid=4 |
Fresh partial: initial order and applicability provisions; Rules 26(b), 26.1 disclosure categories, and 36. Filed August 31, 2017; effective July 1, 2018, with pending-case qualifications. Rule 26.1 printed pp. 47–49/PDF 46–48; Rule 36 pp. 77–79/PDF 76–78. Later corrective orders listed by the official index were not fully recovered/read. Exact consolidated current wording remains H03. |
| S_AZ-P10-S019 |
Arizona Supreme Court, R-23-0019, Rule 56. https://www.azcourts.gov/Portals/0/20/2023%20Rules/R-23-0019%20Final%20Rules%20Order.PDF?ver=E5NytWGHiQjft6qFt_hQdA%3D%3D |
Fresh body: printed pp. 3–4/PDF 2–3. Filed August 24, 2023; effective January 1, 2024. Statements of fact, reply material, and objection procedure read. |
| S_AZ-P10-S020 |
Arizona Supreme Court, R-23-0030, Rule 55(b)(1)(A). https://www.azcourts.gov/Portals/0/20/2023%20Rules/R-23-0030%20Final%20Rules%20Order.PDF?ver=E5NytWGHiQjft6qFt_hQdA%3D%3D |
Fresh body: printed p. 3/PDF 2. Filed August 24, 2023; effective January 1, 2024. Used only for default amount-proof boundary. Later Rule 55(a) changes and default-entry clocks are outside this pass. |
| S_AZ-P10-S021 |
Arizona Supreme Court, R-22-0047, Rule 80(a). https://www.azcourts.gov/Portals/0/20/2023%20Rules/R-22-0047%20Final%20Rules%20Order.PDF?ver=-zb9Dmucwf5bSVbF_bG5_g%3D%3D |
Fresh body: printed p. 3/PDF 2. Filed/dated August 24, 2023; effective January 1, 2024. The introductory recital says a petition was filed December 29, 2023, an internal chronology inconsistency. No correction to that recital is invented; the express order/effective provisions are reported separately. |
| S_AZ-P10-S022 |
Arizona Supreme Court, R-22-0009 electronic-signature order. https://www.azcourts.gov/Portals/0/20/2023%20Rules/R-22-0009%20Final%20RulesOrder.PDF?ver=g9pl_6pSF-l-L55U0BVX0w%3D%3D |
Fresh partial: Justice Rule 109(a), printed p. 8/PDF 7, and relevant electronic-signature text. Effective January 1, 2024. Filing acceptance does not adjudicate authenticity or substantive truth. |
| S_AZ-P10-S023 |
Arizona Supreme Court, R-12-0006, Justice Court Rules of Civil Procedure. https://www.azcourts.gov/Portals/0/20/2012Rules/R120006.pdf |
Fresh partial: Rules 109(c)–(d), 110(b), 121–122, 129, 140(e)–(f). Filed August 30, 2012; effective January 1, 2013. Rule 121 pp. 22–24/PDF 23–25; Rule 140 amount provisions pp. 45–46/PDF 46–47. Later amendments checked through S039; this is an adoption document, not a current consolidated edition. |
| S_AZ-P10-S024 |
Arizona Supreme Court, R-18-0021, Small Claims Rules. https://www.azcourts.gov/Portals/0/20/2019%20Rules/R-18-0021%20Final%20Order.pdf?ver=2019-08-29-150042-927 |
Fresh partial: Rule 12(e), printed p. 10/PDF 9, and surrounding hearing text. Filed August 29, 2019; effective January 1, 2020. Used only for the evidence distinction. Current track eligibility, jurisdictional amount, and later evidence-retention procedure are not decided. |
| S_AZ-P10-S025 |
Arizona Supreme Court, R-14-0004, Rule 111. https://www.azcourts.gov/Portals/0/20/2014%20August%20Rules/R140004.pdf |
Fresh material body: Rule 111(c)–(e), printed pp. 4–5/PDF 3–4. Filed September 2, 2014; effective January 1, 2015. Memorandum-decision citation conditions read. |
| S_AZ-P10-S026 |
Arizona Supreme Court, R-25-0060, future Rule 111 amendment. https://rulesforum.azcourts.gov/DesktopModules/ActiveForums/viewer.aspx?attachmentid=14915&moduleid=9811&portalid=4 |
Fresh body: order and attachment, printed p. 3/PDF 2. Filed August 27, 2026; effective January 1, 2027. Future citation-limitation authority is not applied as current October 27 law. |
2.3 Judicial opinions
| Source ID |
Court-authored document and literal URL |
Actual read scope and source limitations |
| S_AZ-P10-S027 |
Arizona Court of Appeals, Division One, Wells Fargo Bank, N.A. v. Allen, December 4, 2012. https://law.justia.com/cases/arizona/court-of-appeals-division-one-published/2012/1-ca-cv-11-0572.html |
Fresh reproduced opinion: ¶¶1–22 and footnotes; 231 Ariz. 209. Official PDF route failed. Relevant majority and disposition read; Justia headnotes are not the authority. |
| S_AZ-P10-S028 |
Arizona Supreme Court, Certified Collectors, Inc. v. Lesnick, October 14, 1977. https://law.justia.com/cases/arizona/supreme-court/1977/12915-0.html |
Fresh reproduced opinion: entire short majority and disposition, 116 Ariz. 601, 602–603 and footnotes. Official image not located through the inspected archive route. |
| S_AZ-P10-S029 |
Arizona Supreme Court, State v. Parker, March 13, 2013. https://law.justia.com/cases/arizona/supreme-court/2013/cr-10-0196.html |
Fresh reproduced portions: business-record discussion ¶¶27–37, related material, and ¶91 disposition; 231 Ariz. 391. Criminal case used only for shared evidence-rule construction. Official PDF route failed. |
| S_AZ-P10-S030 |
Arizona Court of Appeals, Division Two, Portfolio Recovery Associates, LLC v. Eldred, July 26, 2021. https://law.justia.com/cases/arizona/court-of-appeals-division-two-unpublished/2021/2-ca-cv-2020-0164.html |
Fresh reproduced memorandum: ¶¶1–15 and nonpublication notice. Not precedent; S025 governs possible citation. Official PDF route failed. No later case-specific citation-status clearance. |
| S_AZ-P10-S031 |
Arizona Supreme Court, Holt v. Western Farm Services, Inc., January 11, 1974. https://law.justia.com/cases/arizona/supreme-court/1974/11251-pr-0.html |
Fresh reproduced majority/disposition: 110 Ariz. 276, 277–279. Business account, not a consumer-card holding. Historical evidence rule distinguished from current rules. |
| S_AZ-P10-S032 |
Arizona Court of Appeals, Trimble Cattle Co. v. Henry & Horne, March 1, 1979. https://openjurist.org/122/ariz/44/trimble-cattle-co-v-henry |
Fresh reproduced body: merits and final disposition, 122 Ariz. 44, 47–50. Host-added paragraph numbering and “good law” badge are not court authority or a citator. A later window fetch failed; the original returned body was retained and read. |
| S_AZ-P10-S033 |
Arizona Court of Appeals, Division Two, ChartOne, Inc. v. Bernini, 207 Ariz. 162 (2004). https://cases.justia.com/arizona/court-of-appeals-division-two-published/sa20030107opn-1.pdf?ts=1462294233 |
Fresh reproduced PDF portions: caption; ¶¶1–5, relevant damages discussion including ¶30, and ¶43 disposition. Printed pp. 2–5/PDF 1–4; ¶30 printed pp. 15–16/PDF 14–15; disposition p. 22/PDF 21. Official route failed. Exact issuance day was not established from the read PDF and is held. |
| S_AZ-P10-S034 |
Arizona Supreme Court, Brooks v. Valley National Bank, April 26, 1976. https://law.justia.com/cases/arizona/supreme-court/1976/12334-pr-0.html |
Fresh reproduced majority: 113 Ariz. 169, 170–174 and disposition. Separate concurrence identified; not used as majority reasoning. Mortgage-impound facts are not imported as current sector law. |
| S_AZ-P10-S035 |
Arizona Supreme Court, State v. Strong, September 3, 2024. https://www.azcourts.gov/Portals/0/OpinionFiles/Supreme/2024/CR170201AP.pdf |
Fresh official PDF portions: caption/disposition and ¶¶74–83, printed pp. 18–20/PDF 17–19. Criminal appeal; only business-record and residual-exception analysis used. |
| S_AZ-P10-S036 |
Arizona Supreme Court, Pointe 16 Community Association v. GTIS-HOV Pointe 16, LLC, September 4, 2025. https://www.azcourts.gov/Portals/0/OpinionFiles/Supreme/2025/CV240182PR.pdf |
Fresh official PDF portions: caption, ¶¶6–32, including assignment principles ¶¶13–15 and 22–29; printed pp. 4–12/PDF 3–11. Construction-warranty claim; general assignment principles used with that limit. |
| S_AZ-P10-S037 |
Arizona Supreme Court, Markham Contracting Co. v. Cahava Springs Phase I, Inc., June 17, 2026. https://www.azcourts.gov/Portals/0/OpinionFiles/Supreme/2026/CV250036PR.pdf?ver=ay9XJAVXGJHIiCetWB8_vg%3D%3D |
Fresh official PDF portions: caption and ¶¶7–41; elements at ¶12, printed p. 5/PDF 4; disposition ¶41, p. 15/PDF 14. Dismissal-stage construction case; factual liability remained for remand. |
2.4 Federal text, currency indices, and unrecovered documents
| Source ID |
Issuer/document and literal URL |
Actual read/status and limits |
| S_AZ-P10-S038 |
U.S. Government Publishing Office, United States Code, 2024 edition, Title 15. §1692a: https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapV-sec1692a.htm; §1692g: https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapV-sec1692g.htm; §1602: https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partA-sec1602.htm; §1643: https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1643.htm |
Fresh bodies: §1692a definitions/exclusions; §1692g and notes; §1602’s relevant consumer/card/issuer/unauthorized-use definitions; §1643 and notes. Current OLRC routes failed. 2025–October 27, 2026 amendment/currentness confirmation remains held. Four sections of one Code edition are not four independent corroborating authorities. |
| S_AZ-P10-S039 |
Arizona Judicial Branch rule-amendment indices: https://www.azcourts.gov/rules/rule-amendments-from-recent-rules-agenda-s; https://www.azcourts.gov/rules/recent-amendments/rules-of-civil-procedure; https://www.azcourts.gov/rules/Recent-Amendments/Rules-of-Evidence; https://www.azcourts.gov/rules/Recent-Amendments/Justice-Court-Rules-of-Civil-Procedure |
Fresh index material: relevant amendment entries through the displayed 2026 agenda, and links used to obtain final orders. Index entries do not replace unread attachments or establish absence of other changes. |
| S_AZ-P10-S040 |
Arizona Supreme Court opinion archive and publication notice. https://www.azcourts.gov/opinions/opinions |
Fresh index/notice: displayed year links 2002–2026; statement that bound Arizona Reports contain the final official reports. No inference that older official material does not exist elsewhere. |
| S_AZ-P10-S041 |
Unrecovered Arizona Laws 2000, ch. 263, electronic-transactions enactment lead. https://www.azleg.gov/legtext/44leg/2r/laws/0263.htm; alternate https://www.azleg.gov/legtext/44leg/2r/laws/0263.pdf |
Failed/discovery only: both routes inaccessible through retrieval. The chapter lead came from an indexed official legislative update, https://www.azcourts.gov/Portals/0/40/2000LegUpdate.pdf, whose operative enactment body was not read. Original enactment/transition chain held. |
| S_AZ-P10-S042 |
Arizona Supreme Court R-18-0041, later Rule 807 comment amendment. https://www.azcourts.gov/Portals/0/20/2019%20Rules/R-18-0041%20Final%20Order.pdf?ver=2019-08-29-150127-520; alternate public forum https://rulesforum.azcourts.gov/Rules-Forum/aft/919 |
Failed body: final-order route returned 404; alternate timed out. Official index describes a comment amendment effective January 1, 2020. Its body was not read and is not substituted for S012’s operative Arizona rule. |
| S_AZ-P10-S043 |
Court-linked Westlaw Arizona Rules compilation. Rule 1006: https://govt.westlaw.com/azrules/Document/NEE68B42074FA11EFBDD4F0F34F436841?contextData=%28sc.Default%29&originationContext=documenttoc&transitionType=CategoryPageItem&viewType=FullText; Rule 801: https://govt.westlaw.com/azrules/Document/N1A0EDE1074FB11EFBDD4F0F34F436841?contextData=%28sc.Default%29 |
Failed body: both returned 403. Operative selected amendments were recovered from official final orders S014–S015. No claim of reading this consolidated current publisher text. |
2.5 Failed-route and recovery ledger
3. Published-case and posture register
The following are the actual cases read, not a required-case quota. The register distinguishes the court’s disposition from the substantive result it did not decide.
| Case row |
Source; posture and material facts |
Holding/disposition used |
Limits and later material actually read |
| K01 |
S027, Allen — creditor’s summary judgment on credit-card debt; generic affidavit, inadequately connected agreement, and unexplained records. |
¶¶16–22: creditor’s own admissible proof had to support judgment; reversed, fee award vacated, remanded. |
No final merits victory for the debtor. Historical Rule 56 references must be mapped to current provisions; S019 now expressly addresses limited reply evidence. |
| K02 |
S028, Lesnick — purported assignee sued on a business obligation; transfer failed to identify essential relationships and debt. |
116 Ariz. at 602–603: deficient assignment evidence supported affirmance on a ground different from the trial court’s unauthorized-practice rationale. |
Unauthorized practice and the original creditor’s recovery were not decided. Identification principle freshly found in S036 ¶22. |
| K03 |
S029, Parker — criminal appeal involving issuer transaction information and other records. |
¶¶28–33: knowledgeable testimony about ordinary record creation and reliance supported admission; accurate reproduction did not become inadmissible merely because produced for litigation. |
Not a purchased-consumer-debt case. Older rule version; current 803(6) text controls. S035 ¶¶79–80 applies the foundation principle. |
| K04 |
S030, Eldred — debt buyer’s summary judgment; buyer and seller evidence, account-level sale material, statements, payments. |
¶¶7–14 accepted the record showing and account-stated reasoning; ¶15 affirmed. |
Memorandum, not precedent. Its validation-notice silence discussion does not address §1692g(c). No universal predecessor-record exception or silence rule extracted. |
| K05 |
S031, Holt — contested trial on agricultural purchases and a running account. |
110 Ariz. at 278–279: no account stated on those facts; open-account judgment nevertheless supported because payments extinguished the opening debit and remaining invoices proved the account. |
Historical Rule 44(q) is not current Rule 803(6). The payment-allocation facts are not imposed on every card account. |
| K06 |
S032, Trimble — two accounting-fee accounts after bench trial. |
122 Ariz. at 47–49: assent inferable for one final account; insufficient item/detail proof for the other. Affirmed in part, reversed in part, costs remanded. |
No fixed silence period creates universal assent. Host-added paragraph numbers are not used as official pinpoints. |
| K07 |
S033, ChartOne — special actions after liability phase of an implied-contract trial; court attempted special-master damages determination. |
¶30 states contract/breach/damages burden; ¶43 vacates challenged orders and permits damages trial. |
Historical Rule 53 procedure is not imported. Exact issuance day remains unverified; reported year is 2004. |
| K08 |
S034, Brooks — mortgage-impound dispute resolved against borrower. |
113 Ariz. at 174: a specific contract governing the relationship barred the asserted unjust-enrichment theory. |
General contract/equity boundary only. Separate concurrence not substituted for majority. Current mortgage servicing law is excluded. |
| K09 |
S035, Strong — criminal appeal; officers possessed third-party phone records but could not establish their recordkeeping foundation. |
¶¶74–83: possession and an undisputed phone-number connection did not establish the business-record or residual-exception predicates; exclusion upheld. |
No criminal burden, confrontation rule, or harmless-error standard imported into debt litigation. |
| K10 |
S036, Pointe 16 — summary judgment against assignee of accrued warranty claims. |
¶¶13–15, 22–30: assignment principles and construction of the actual anti-assignment clause; ¶¶31–32 vacate/reverse relevant portions and remand. |
Does not validate every debt sale or every contractual assignment restriction. |
| K11 |
S037, Markham — dismissal of unjust-enrichment complaint concerning improvements arranged through a third party. |
¶12 elements; ¶¶21–39 distinguish landlord-specific rule; ¶41 reverses dismissal, vacates appellate memorandum, remands. |
Pleaded facts were assumed at dismissal; unjust enrichment was not finally proved. No consumer-debt recovery awarded. |
The two particularly useful current comparisons are Parker/Strong for the difference between a qualified foundation and mere possession, and Lesnick/Pointe 16 for assignment identification and the effect of actual transfer language. law.justia.com+3
4. Atomic claim and evidence register
4.1 Causes, terms, party identity, and assignment
| Claim ID |
Actor, predicate, required proof or consequence |
Exact authority |
Basis, confidence, and limits |
| S_AZ-P10-C001 |
This pass’s consumer-account examples concern personal, family, or household transactions. Consumer purpose must be established where the applicable rule uses that predicate. |
S023, Rule 121(a)(3)(B); S038, §1692a(5) |
D; high within versions. Common-law contract cases involving businesses are used only for general principles. |
| S_AZ-P10-C002 |
A contract claimant bears proof of contract existence, breach, and resulting damages; damages require reasonable certainty. |
S033, ¶30 |
H; high, bounded posture. Does not decide any particular contract’s formation or enforceability. |
| S_AZ-P10-C003 |
For a qualifying credit-card account, acceptance may occur as the agreement provides, by specified signed record, or by cardholder/authorized-user use. |
S001, §44-7802 |
D; high. No universal wet-ink requirement; applicable terms and attributable use still need proof. |
| S_AZ-P10-C004 |
Arizona’s cardholder-liability provision covers charges and interest incurred by the cardholder or authorized user, and excludes unauthorized-user charges and interest. |
S001, §§44-7801(1)–(2), 44-7803 |
D; high. Actual authority, identity, governing law, and federal interaction remain factual/legal predicates. |
| S_AZ-P10-C005 |
In an uncontested credit-card action, the creditor may establish the amount through a copy of the issuer’s final billing statement or the specified issuer electronic record. |
S001, §§44-7801(7), 44-7804, first sentence |
D; high. This concerns amount; it does not expressly adjudicate every ownership or liability issue. |
| S_AZ-P10-C006 |
In a contested credit-card action, the court weighs the evidence as required by law. |
S001, §44-7804, second sentence |
D; high. The uncontested amount shortcut is not a universal contested-trial rule. |
| S_AZ-P10-C007 |
Contracted card interest may be established through terms and conditions or an issuer billing statement stating the rate, subject to the stated statutory cross-references. |
S001, §44-7805; §§44-1205, 44-6002 |
D; high text. Issuer type, governing law, applicable subsection, rate period, and federal rate issues remain necessary. |
| S_AZ-P10-C008 |
A charge’s inclusion in a balance does not establish its authorization. Section 44-1205’s card-account provisions condition specified charges on the applicable contractual/statutory framework. |
S001, §44-1205(C)–(G); §44-7805 |
D/I; bounded. No universal consumer-debt fee schedule, default rate, or collection-fee entitlement established. |
| S_AZ-P10-C009 |
UETA applies within its statutory scope to parties agreeing to electronic transactions; other substantive law remains relevant. |
S001, §§44-7003, 44-7005 |
D; high current text. Agreement may be assessed from context and conduct; old-record transition remains H05. |
| S_AZ-P10-C010 |
Electronic attribution depends on the person’s or electronic agent’s act, with effect determined from context and applicable law. |
S001, §§44-7002(8), 44-7009 |
D; high. A typed name or account login does not conclusively resolve attribution. |
| S_AZ-P10-C011 |
Electronic form alone is not a ground to deny specified legal effect or exclude an electronic record from evidence. |
S001, §§44-7007, 44-7013 |
D; high. Authentication, hearsay, and substantive sufficiency remain separate. |
| S_AZ-P10-C012 |
An open-account claimant must prove the account’s correctness and its items. |
S031, 110 Ariz. at 278; S032, 122 Ariz. at 48–49 |
H; high. Does not prescribe one universal record format. |
| S_AZ-P10-C013 |
In Holt, payments applied to oldest items extinguished the unsupported opening debit; supported later invoices then established the remaining account. |
S031, 110 Ariz. at 278–279 |
H; fact-specific. No automatic allocation rule is imposed on the fictional card ledgers. |
| S_AZ-P10-C014 |
Account stated requires an actual agreement to an adjusted balance; simply furnishing a statement is insufficient. |
S031, 110 Ariz. at 278 |
H; high. Finality and assent are factual predicates. |
| S_AZ-P10-C015 |
Silence can support an assent inference in context, but no arbitrary period of nonobjection universally equals agreement. |
S032, 122 Ariz. at 47–48 |
H; high. Rebutting circumstances, receipt, prior objections, and the account’s finality matter. |
| S_AZ-P10-C016 |
An unjust-enrichment claimant must satisfy the five identified elements, including lack of justification and lack of an available legal remedy. |
S037, ¶¶11–12 |
H; high. Dismissal-stage construction case; consumer application requires separate facts. |
| S_AZ-P10-C017 |
A specific contract governing the parties’ relationship can preclude unjust-enrichment recovery on that subject. |
S034, 113 Ariz. at 174 |
H; bounded. A contract with a third party is not automatically the same relationship; compare S037, ¶¶27–39. |
| S_AZ-P10-C018 |
Alternative or inconsistent claims may be pleaded; pleading alternatives does not itself establish either theory or authorize duplicate recovery. |
S016, Rule 8(d)(2)–(3); C002, C016 |
D/I; high rule, conditional application. |
| S_AZ-P10-C019 |
An action must be prosecuted by the real party in interest, subject to Rule 17(a)’s listed representative categories. |
S016, Rule 17(a)(1)–(2) |
D; high selected text. Ownership and authorized representative status require evidence. |
| S_AZ-P10-C020 |
After a real-party objection, Rule 17(a)(3) provides reasonable time for ratification, joinder, or substitution before dismissal on that ground. |
S016, Rule 17(a)(3) and comment |
D; high. Not guaranteed cure of every fabricated, nonexistent, or substantively defective claim. |
| S_AZ-P10-C021 |
Following transfer of a party’s interest during an action, the action may continue by or against that party unless the court orders substitution or joinder. |
S016, Rule 25(c), printed p. 80/PDF 112 |
D; high. Does not prove a transfer occurred or retroactively decide pre-suit ownership. |
| S_AZ-P10-C022 |
Capacity, representative authority, and legal existence ordinarily need not be pleaded except as required for jurisdiction; a challenge requires the specific denial described by the rule. |
S016, Rule 9(a) |
D; high selected text. Capacity is distinct from title and the merits of the debt. |
| S_AZ-P10-C023 |
A valid assignment requires evidence of intent to transfer an identifiable right or obligation and the necessary contractual requisites. |
S028, 116 Ariz. at 602–603 |
H; high. The deficient paper in that record was not cured by extrinsic evidence. |
| S_AZ-P10-C024 |
For successive sales, the evidence must connect the asserted obligation through each material transfer. Generic documents, mismatched schedules, exclusions, or unexplained identifiers can leave that proposition unproved. |
S028, at 603; S036, ¶¶13, 22; S016, Rule 17(a) |
I; conditional. No universal demand for a particular bill-of-sale format or every portfolio record. |
| S_AZ-P10-C025 |
Assignment restrictions require construction of the actual clause and assigned subject. Pointe 16 distinguished agreement rights from accrued claims under its clause. |
S036, ¶¶21–30 |
H; bounded. Not a blanket invalidation of anti-assignment clauses. |
| S_AZ-P10-C026 |
Assignment of a chose in action does not prejudice specified defenses or setoffs existing at notice of assignment, subject to the section’s negotiable-instrument exception. |
S001, §44-144 |
D; high. Notice date and transaction classification matter. |
| S_AZ-P10-C027 |
Section 44-145 supplies a narrower consumer-obligation defense rule with 90-day receipt/notice predicates, written certified-mail notice language, and express exclusions. |
S001, §44-145(A)–(C) |
D; high text; application held. Not a universal rule for every card transaction; incorporated UCC definitions and actual sale/lease facts remain H12. |
| S_AZ-P10-C028 |
A servicing or agency agreement can establish authority different from ownership. Whether the actor may sue in its own name requires the actual right and Rule 17 category. |
S001, §44-7801(7); S016, Rule 17(a); S028 |
I; conditional. Licensing and collector status are separate deferred questions. |
| S_AZ-P10-C029 |
Purchase consideration paid for an assigned asset is not, merely by arithmetic, a consumer payment or release of the assigned obligation. |
S036, ¶13; S028, at 602–603; M02 stipulations |
I/X; conditional. Actual sale or settlement terms could change the result. |
4.2 Evidence, records, authentication, and summaries
| Claim ID |
Actor, predicate, required proof or consequence |
Exact authority |
Basis, confidence, and limits |
| S_AZ-P10-C030 |
A fact witness needs a sufficient personal-knowledge basis for the testimony offered. |
S008, Rule 602 |
D; high. Knowledge of recordkeeping differs from witnessing every transaction. |
| S_AZ-P10-C031 |
Authentication requires sufficient evidence that the item is what its proponent claims. |
S008, Rule 901(a), (b)(1), (4), (9) |
D; high. Authentication does not itself prove truth or liability. |
| S_AZ-P10-C032 |
A qualifying notarized acknowledgment can address authenticity. |
S008, Rule 902(8) |
D; high. Notarization does not establish every factual assertion or assignment link. |
| S_AZ-P10-C033 |
An out-of-court assertion offered for its truth needs a nonhearsay basis or applicable exception. |
S008, Rules 801(a)–(c), 802 |
D; high. Purpose of the offered statement matters. |
| S_AZ-P10-C034 |
Business records require near-time knowledgeable input, ordinary-course keeping, and regular practice. |
S009, Rule 803(6)(A)–(C) |
D; high. A litigation balance assertion alone does not establish those predicates. |
| S_AZ-P10-C035 |
Foundation may be shown by a custodian, another qualified witness, or a qualifying certification. |
S009, Rule 803(6)(D) |
D; high. Job title or an oath alone is insufficient. |
| S_AZ-P10-C036 |
Once the proponent establishes A–D, the opponent bears the specified untrustworthiness showing under E. |
S009, Rule 803(6)(E), comment; effective January 1, 2015 |
D; high. This evidentiary allocation does not transfer the plaintiff’s ultimate liability burden. |
| S_AZ-P10-C037 |
A domestic business-record certification requires the specified foundation and reasonable written notice plus inspection opportunity. |
S008, Rule 902(11); S009, Rule 803(6)(D) |
D; high. Certification is contestable; foreign certification has different qualifications in 902(12). |
| S_AZ-P10-C038 |
Parker permits a qualified witness to explain ordinary records incorporating third-party input; personal assembly of every entry is unnecessary. |
S029, ¶¶28–33 |
H; bounded. Does not create an automatic exception for every purchased portfolio. |
| S_AZ-P10-C039 |
Possession and use of another business’s records do not alone establish its ordinary recordkeeping predicates. |
S035, ¶¶75–80 |
H; high. Officers in that record lacked the necessary knowledge. |
| S_AZ-P10-C040 |
Eldred accepted its particular buyer/seller foundation and account-linkage showing. |
S030, ¶¶7–9 |
M; limited. Neither an issuer affidavit nor its absence is made universally dispositive by this memorandum. |
| S_AZ-P10-C041 |
Each hearsay layer needs a qualifying basis. |
S008, Rule 805 |
D; high. Storing an outsider’s assertion in a business file is not sufficient by itself. |
| S_AZ-P10-C042 |
Rules 902(13)–(14) permit specified electronic-system/copy authentication by qualified certification and notice. |
S010, rules and comments; effective January 1, 2018 |
D; high. Authentication-only certification does not establish Rule 803(6). |
| S_AZ-P10-C043 |
Accurate ESI output can qualify as an original; duplicates and other-content proof have stated conditions and exceptions. |
S011, Rules 1001–1004; S008, Rule 1003 |
D; high. Genuine authenticity disputes or unfairness can matter. No universal paper-original requirement. |
| S_AZ-P10-C044 |
Rule 1006 permits an evidentiary summary of voluminous admissible material, whether or not the underlying material is introduced, with access to originals/duplicates. |
S014, Rule 1006(a)–(b), effective January 1, 2025 |
D; high. The summary cannot cure inadmissible or nonexistent underlying evidence. |
| S_AZ-P10-C045 |
A Rule 107 illustrative aid assists understanding but is not evidence; jury-deliberation use has stated consent/good-cause conditions. |
S014, Rule 107(a)–(e), effective January 1, 2025 |
D; high. A balance chart is not automatically substantive proof. |
| S_AZ-P10-C046 |
Fairness may require contemporaneous introduction of related writing or recorded-statement portions, including over a hearsay objection. |
S013, Rule 106, effective January 1, 2024 |
D; high. Requires the actual offered portion and fairness predicate. |
| S_AZ-P10-C047 |
A qualifying statement admissible against a predecessor can also be admissible against a party whose claim, defense, or potential liability is directly derived from that predecessor. |
S015, Rule 801(d)(2) added paragraph; S008, 801(d)(2)(A)–(E) |
D; high; effective January 1, 2025. The statement must be offered against the appropriate opposing party; not a shortcut for a claimant’s own assertions. |
| S_AZ-P10-C048 |
Evidentiary error ordinarily requires timely, specific objection or a sufficient offer of proof; definitive rulings need not be renewed. |
S008, Rule 103(a)–(b) |
D; high. Fundamental-error text is not routine permission to omit objections. |
| S_AZ-P10-C049 |
Residual admission requires sufficient trustworthiness, comparative probative value after reasonable efforts, and the rule’s notice/filing conditions. |
S012, Rule 807(a)–(b); S035, ¶¶81–83 |
D/H; high operative text. It is not an automatic cure for a failed business-record foundation. |
4.3 Pleading, disclosure, summary judgment, trial, and defenses
| Claim ID |
Actor, predicate, required step or consequence |
Exact authority |
Basis, confidence, and limits |
| S_AZ-P10-C050 |
Pleadings state claims and responses; damages allegations are excepted from Rule 8(b)(6)’s admission rule. Allegations and attached exhibits are not automatically trial proof. |
S016, Rules 8(a)–(b), 10(c); S033, ¶30 |
D/I; high selected text. Fraud/mistake pleading particulars are separately addressed in Rule 9(b). |
| S_AZ-P10-C051 |
Verification is not universally required. Applicable statutes/rules determine when verification or a qualifying declaration is necessary. |
S016, Rule 8(i); S023, Rule 109(c)–(d); S022, Rule 109(a) |
D; high selected text. Electronic filing/signature acceptance does not determine evidentiary truth. |
| S_AZ-P10-C052 |
Justice-court allegations identified by §22-216 must be written and signed; an objection to an affidavit-verified account must identify unjust items and particulars. |
S002, §22-216(A)(2)–(3), (8)–(11); S005, §22 |
D; high. Current text does not universally require the denying party’s affidavit. No automatic merits consequence inferred from a pleading defect. |
| S_AZ-P10-C053 |
A justice-court complaint on an assigned debt must identify the original owner. |
S023, Rule 110(b)(1) |
D; high selected text. Naming the owner is a pleading requirement, not proof of the chain. |
| S_AZ-P10-C054 |
In a contested justice-court consumer-debt case, the plaintiff must disclose available agreement/billing material, ownership evidence if assigned, and available last-payment information. |
S023, Rule 121(a)(3)(B)(i)–(iv), (b)–(c) |
D; high selected text. “If available” is not an exemption from the ultimate proof burden. |
| S_AZ-P10-C055 |
The adopted superior-court disclosure text requires factual/legal bases, witnesses, damages computation, and relevant material. |
S018, Rule 26.1(a)–(c) |
D; partial currentness. Exact consolidated 2026 wording and corrective-order chain remain H03; no calendar calculated. |
| S_AZ-P10-C056 |
Discoverability and admissibility differ. Superior discovery is subject to relevance/proportionality and privilege; justice rules also distinguish discovery from trial admissibility. |
S018, Rule 26(b)(1); S023, Rule 122(a) |
D; bounded by H03. No discovery demand or entitlement in an actual case is determined. |
| S_AZ-P10-C057 |
Formal Rule 36 admissions can conclusively establish matters in the pending action unless withdrawal/amendment is permitted under the rule. |
S018, Rule 36(a)(1), (b) |
D; selected text. A collection-notice nonresponse is not a Rule 36 admission. Actual request/service/response facts are held. |
| S_AZ-P10-C058 |
Summary judgment requires no genuine dispute of material fact and entitlement as a matter of law. |
S016, Rule 56(a) |
D; high selected text. A correct total does not eliminate disputes about liability or title. |
| S_AZ-P10-C059 |
A plaintiff moving for summary judgment retains its affirmative burden to present admissible evidence supporting the claim. |
S027, ¶¶16–20 |
H; high. Nonresponse does not repair an unsupported plaintiff’s motion. |
| S_AZ-P10-C060 |
Summary-judgment affidavits require personal knowledge, admissible facts, competency, and properly authenticated copies of referenced documents. |
S016, Rule 56(c)(5)–(6); S027, ¶¶18–20 |
D/H; high. A conclusory sworn balance is not automatically sufficient. |
| S_AZ-P10-C061 |
Once a motion is properly supported, an opponent cannot rely only on pleading denials and must identify specific facts creating a genuine issue. |
S016, Rule 56(e) |
D; high. The qualifying “properly supported” predicate remains essential. |
| S_AZ-P10-C062 |
Current selected Rule 56 amendments require specific record citations and concise evidentiary objections; limited reply evidence may rebut new response facts. |
S019, Rule 56(c)(3)–(4), effective January 1, 2024 |
D; high. Allen’s older reply-evidence discussion is not treated as a categorical modern prohibition. |
| S_AZ-P10-C063 |
A party lacking essential opposition evidence may seek Rule 56(d) relief with specified support; the request alone does not extend response obligations. |
S016, Rule 56(d)(1)–(5) |
D; high selected text. No actual deadline or entitlement to relief calculated. |
| S_AZ-P10-C064 |
Justice Rule 129 requires an admissible factual showing and legal entitlement; nonresponse by a party without the proof burden does not itself justify judgment. |
S023, Rule 129(a)–(e) |
D; high selected text. Liability and amount can require separate adjudication. |
| S_AZ-P10-C065 |
Superior default judgment without a hearing on a sum certain requires the rule’s predicates and an amount affidavit; fees need their own lawful basis and support. |
S020, Rule 55(b)(1)(A); S016, 55(b)(1)(B)–(C), (2)(D), (3) |
D; high amount boundary. No default-entry, service, or protected-person determination made. |
| S_AZ-P10-C066 |
Justice Rule 140(e) requires an amount affidavit and attachments proving the claim; contractual attorney fees require the specified contract/support, and the court may require a hearing. |
S023, Rule 140(e)–(f) |
D; high selected text. No default clock or actual judgment entitlement inferred. |
| S_AZ-P10-C067 |
If a matter is properly in small claims, formal evidence rules do not apply; nonprivileged relevant evidence remains subject to reliability, prejudice, confusion, and time limits. |
S024, Rule 12(e) |
D; high selected text. Small-claims eligibility is not determined here. |
| S_AZ-P10-C068 |
Payment, release, accord and satisfaction, failure of consideration, and other listed defenses require appropriate pleading; their factual basis remains to be proved. |
S016, Rule 8(c); S001, §44-144 |
D/I; bounded. This does not allocate every disputed defense’s ultimate persuasion burden or prove a discharge. |
| S_AZ-P10-C069 |
Compromise offers and negotiations have restricted evidentiary uses; an actual settlement’s existence/performance is a different evidentiary purpose requiring analysis. |
S008, Rule 408(a)–(b) |
D/I; conditional. No blanket admission or exclusion of every settlement document. |
| S_AZ-P10-C070 |
Disputed agreements between litigating parties or counsel must satisfy Rule 80(a)’s writing or specified recorded-agreement routes. |
S021, Rule 80(a) |
D; high operative text. Not a universal substitute for formation analysis of every pre-suit settlement. |
| S_AZ-P10-C071 |
For the covered federal validation setting, failure to dispute under §1692g cannot be construed by a court as an admission of liability. |
S038, §1692g(c), with §1692a(3), (5)–(6) |
D; high 2024 text; later currentness held. Eldred did not address this clause; no universal silence-based admission is adopted. |
| S_AZ-P10-C072 |
In a card issuer’s enforcement action, §1643(b) places the stated authorized-use/unauthorized-use-condition burden on the issuer; subsection (c) preserves lower liability under other law/agreement. |
S038, §§1602(l)–(p), 1643(a)–(d); S001, §44-7803 |
D; high 2024 federal text; later currentness held. Not extended automatically to every debt-buyer posture. |
4.4 Currentness, conditional models, and additional electronic-record clauses
| Claim ID |
Precise assertion |
Authority or stipulated inputs |
Basis/confidence/hold |
| S_AZ-P10-C073 |
The read 2012 act added §§44-7801–7806; approval, filing, and general effectiveness were different events: May 9, May 10, and August 2, 2012. |
S004 §1 and notation; S006 2012 row |
D; high. No old-account transition holding inferred. |
| S_AZ-P10-C074 |
The read §22-216 amendment was approved/filed June 19, 2013 and effective January 1, 2014. |
S005 §§22, 64 and notation; S002 |
D; high. Older verification wording is not treated as current. |
| S_AZ-P10-C075 |
Arizona’s general statute states that retroactivity requires express declaration. |
S003, §1-244 |
D; high. Specific procedural/evidentiary application questions remain separate. |
| S_AZ-P10-C076 |
Memorandum decisions are not precedent. Persuasive citation requires the Rule 111(c)(1)(C) conditions, including post-January 1, 2015 issuance, no adequately addressing published opinion, and no depublication. |
S025, Rule 111(c)(1)–(4) |
D; high selected text. Other authorized uses and copy/link requirements remain applicable. |
| S_AZ-P10-C077 |
R-25-0060 adds specified court-ordered limits on persuasive citation of memoranda after denial of review, effective January 1, 2027. |
S026, order and Rule 111(g)(2) |
D; high; future-effective. Not October 27, 2026 law. |
| S_AZ-P10-C078 |
Fresh access to the 2024 federal Code did not establish a complete 2025–October 2026 amendment check. |
S038; failed OLRC routes |
G; observed limit. H04 remains open. |
| S_AZ-P10-C079 |
Selected final rule amendments were read, but the entire superior disclosure correction chain and consolidated current publisher text were not. |
S018, S039, S043 |
G; observed limit. H03; no all-rules currency certificate. |
| S_AZ-P10-C080 |
The fictional models assume applicable Arizona law; actual choice-of-law, issuer, forum, and territorial facts were not obtained. |
Model stipulations; S001 §44-7806 and UETA scope |
G/X. No actual interstate or tribal application determined. |
| S_AZ-P10-C081 |
M01’s stipulated 30-day simple interest is $11.84; claimed balance including disputed $35 is $996.84. |
M01 inputs; C002, C007–C008 |
X; arithmetic verified. Lawfulness of the rate/fee is conditional. |
| S_AZ-P10-C082 |
Without established interest/fee authority, M01 remains $950 + I + F; the calculation does not establish a lawful zero-interest alternative. |
M01 inputs and missing terms |
X/G. H09. |
| S_AZ-P10-C083 |
M02’s positive title branch depends on matching inclusion at both transfers; a missing/excluded account prevents the matrix alone from proving the chain. |
M02 documents; C019–C025 |
X/I. No actual assignment determination. |
| S_AZ-P10-C084 |
M02’s credited consumer payment reduces $1,050 to $950; $120 and $80 purchase prices remain separate acquisition consideration. |
M02 inputs; C029 |
X; exact USD arithmetic. Contractual treatment stipulated. |
| S_AZ-P10-C085 |
M03 requires separate authentication, hearsay-foundation, amount, and title showings; certification or a summary does not merge them. |
C030–C049, C058–C064; M03 facts |
X/I. Actual admissibility and sufficiency remain judicial questions. |
| S_AZ-P10-C086 |
M03’s full ledger totals $700; if $400 of the opening balance lacks proof, the supported-number subtotal is $300, not an adjudicated recoverable minimum. |
M03 inputs; C012–C013, C058–C060 |
X; arithmetic verified; legal outcome held. |
| S_AZ-P10-C087 |
M04’s net settled cash receipts are $600; before any release, the accounting residual is $400. |
M04 receipt/reversal inputs |
X; exact arithmetic. Cash movement and legal release are separate. |
| S_AZ-P10-C088 |
Under M04’s stipulated valid release condition, $400 is released after $600 cleared; if the condition/authority is disputed, the $400 residual is not automatically collectible. |
M04 stipulations; C026, C068–C070 |
X/I. H10; no actual settlement enforceability decision. |
| S_AZ-P10-C089 |
Where the UETA writing-delivery provision applies, the electronic information must meet its retention/presentation conditions; inhibiting storage or printing has the stated enforceability consequence. |
S001, §44-7008(A)–(D) |
D; high text. Other law’s prescribed method and permitted variation matter. |
| S_AZ-P10-C090 |
Electronic retention can satisfy original/retention requirements when accuracy and later accessibility conditions are met. |
S001, §44-7012(A)–(D) |
D; high text. Later laws prohibiting electronic retention and actual record integrity remain relevant. |
5. Twenty distinct fictional postures
All actors and records below are fictional. None is an actual borrower, provider, account, or case assessment.
| Posture |
Fictional facts |
Rule/holding and needed evidence |
Conditional consequence and uncertainty |
| P01 |
Original issuer has attributable card use but no wet-ink application. |
C003, C010–C011: agreement/use and attribution evidence. |
Signature absence alone does not resolve liability; disputed terms and authorized use remain. |
| P02 |
Issuer offers a 2026 generic agreement for an account opened years earlier. |
C002, C007, C059: applicable-version and amendment linkage. |
Agreement may be relevant, but its connection and disputed rate are unproved without further evidence. |
| P03 |
Plaintiff offers the issuer’s final statement; defendant contests amount. |
C005–C006. |
Uncontested statutory amount route cannot simply be carried over to the contested posture. |
| P04 |
Open-account ledger starts with a lump sum; later credits may cover all old items. |
C012–C013: underlying items and lawful allocation. |
Holt may be informative, but allocation and supported remaining items must be established. |
| P05 |
Monthly statements continued while purchases continued; consumer disputes finality. |
C014. |
Mere running statements do not automatically establish an account stated. |
| P06 |
A final bill was received after a long relationship ended; earlier written objections exist. |
C015, C071. |
Silence is evaluated with countervailing evidence; no fixed silence period or validation admission assumed. |
| P07 |
One buyer presents a generic bill of sale without an account link. |
C023–C024. |
Ownership of this obligation remains unproved by that package alone. |
| P08 |
Two sales are shown, but the second schedule identifies a different account. |
C024, C083. |
A competent mapping or other proof is needed; mismatch does not by itself establish that no assignment ever occurred. |
| P09 |
Servicer sues in its own name while agreement names another owner. |
C019, C022, C028. |
Agency, representative category, and actual rights need separate proof. |
| P10 |
Original plaintiff sells its interest after filing. |
C021. |
Rule 25(c) may permit continuation; no automatic dismissal or automatic substitution inferred. |
| P11 |
Buyer witness explains integration, ordinary reliance, and actual source systems, but never worked for seller. |
C035, C038, C040. |
Prior employment is not a universal prerequisite; actual competence and record-specific foundation still matter. |
| P12 |
Witness says only that a reputable bank supplied the balance. |
C034–C039, C060. |
Reputation and possession alone may leave the foundational facts missing. |
| P13 |
Spreadsheet embeds an outsider’s email saying a charge was authorized. |
C033, C041. |
Each assertion and its offered purpose need a qualifying basis. |
| P14 |
Electronic acceptance log is genuine, but identity of the user is disputed. |
C010, C031, C042. |
Authentic system output does not conclusively prove who acted or with what authority. |
| P15 |
Ledger adds interest and a new “assignment fee.” |
C007–C008, C029. |
Arithmetic can be correct while authority for additions remains unproved. |
| P16 |
Consumer paid an authorized recipient, but plaintiff’s ledger omits the payment. |
C012, C026, C068. |
Receipt, authority, crediting terms, and allocation require reconciliation; ledger omission is not proof of nonpayment. |
| P17 |
Settlement payment was provisionally posted, reversed, and replaced. |
C068–C070, C087–C088. |
Net cleared receipts and release conditions must be analyzed separately. |
| P18 |
Consumer asserts mistaken identity or bankruptcy discharge. |
C004, C072; H02, H10. |
Identity proof is within this gateway; discharge scope/order and bankruptcy consequences remain deferred. |
| P19 |
Attorney’s chart totals a large set of records but underlying material is unavailable. |
C044–C045. |
Calling the chart a summary does not establish Rule 1006 predicates; it may only be an illustrative aid, if otherwise allowed. |
| P20 |
Justice-court defendant generally denies an affidavit-verified account without identifying challenged items. |
C052, C054, C064. |
The specific pleading requirement needs attention; no automatic debt validity or judgment consequence is inferred. |
6. Four fully worked fictional models
M01 — Original-creditor account, disputed interest, and disputed fee
Actors: fictional Issuer O and Consumer X.
Assumed governing framework: Arizona contract/card law applies; this is a contested action. No limitations or court-response clock is calculated.
Documents assumed for the positive arithmetic branch: an attributable agreement; records supporting the opening principal, purchases, return, and payment; an applicable term providing lawful 12% annual simple interest, actual/365, on the specified constant principal for the specified period. The $35 fee is separately disputed.
Fictional events
- January 1, 2026: supported opening principal $1,000.
- January 1: purchases $250 and merchandise return $50 are posted before the interest period begins.
- Interest runs from January 1 to January 31, excluding January 31: 30 elapsed calendar days.
- January 31: $250 actual payment is credited.
- For this example, the established payment allocation pays accrued interest first, then principal.
- A separate $35 fee is posted after that payment. Its authority is not stipulated.
Calculation
Plain text
Principal at start of interest period
= $1,000.00 + $250.00 − $50.00
= $1,200.00
Interest, before rounding
= $1,200.00 × 0.12 × 30 / 365
= $11.835616438...
Stipulated rounding: nearest cent, once at period end
Interest = $11.84
Payment allocated to interest = $11.84
Payment allocated to principal = $250.00 − $11.84 = $238.16
Principal after payment = $1,200.00 − $238.16 = $961.84
Remaining interest = $0.00
Claimed fee = $35.00
Claimed total = $961.84 + $0.00 + $35.00 = $996.84
| Component |
Opening/additions |
Credits |
Conditional closing |
| Principal |
$1,000 + $250 |
$50 return + $238.16 payment |
$961.84 |
| Interest |
$11.84 |
$11.84 payment |
$0 |
| Fee |
$35 disputed |
$0 |
$35 disputed |
| Total |
$1,296.84 |
$300.00 |
$996.84 claimed |
Positive branch: if the terms, lawful applicability, records, and attribution are established, the interest arithmetic is supported. The fee still requires its own basis.
Adverse branch: if the offered agreement is the wrong version, or rate/base/period authority is missing, the legally supported amount is not established by inserting 12%. The unresolved formula is:
Plain text
$1,000 + $250 − $50 − $250 + I + F
= $950 + I + F
I is legally supported interest and F legally supported fees, neither assumed to be zero merely because the plaintiff’s offered proof is inadequate. No default statutory rate is supplied.
Burden and evidence: C002, C006–C008, C010, C012, C058–C060; model claims C081–C082. Sources: S001 §§44-7802–7805; S027 ¶¶16–20; S016 Rule 56(c)(5). This is not a determination that $996.84 or $961.84 is owed.
M02 — Two assignments, account inclusion, and servicing authority
Actors: fictional Originator O, Buyer A, Buyer B, Servicer S, and Consumer Y.
Obligation identifier: fictional Q-104, used only within this example.
Balance before the sales
The stipulated supported January 31, 2026 balance is:
Plain text
Principal $1,000 + interest $40 + authorized fee $10 = $1,050
On February 5, O actually credits a $100 consumer payment. The stipulated lawful allocation is interest, then fee, then principal:
Plain text
Interest credit = $40
Fee credit = $10
Principal credit = $100 − $40 − $10 = $50
Remaining principal = $1,000 − $50 = $950
Remaining interest = $0
Remaining fees = $0
Remaining total = $950
No later interest or fee is included in this example’s claimed balance; that is a factual modeling assumption, not a rule that accrual stops on sale.
Chain/date/account-inclusion matrix
| Date |
Fictional document/event |
Positive proof branch |
Adverse branch |
| Before February 10 |
O’s agreement and account records |
Connect Consumer Y and Q-104 to O’s right. |
Similar name or branded statement without account attribution leaves identity/right unresolved. |
| February 10 |
O→A sale instrument |
Expressly transfers accounts identified in the associated schedule. |
Seller authority, effective date, exclusions, or schedule connection missing. |
| February 10 |
First schedule |
Identifies Q-104, with competent evidence connecting it to the instrument. |
An unlinked spreadsheet does not establish inclusion by itself. |
| March 20 |
A→B sale instrument |
Transfers the same identified obligation and applicable rights. |
A’s title or the transferred scope remains unproved. |
| March 20 |
Second schedule |
Identifies Q-104 consistently, or a renumbering is competently explained. |
Schedule says Q-140, or Q-104 is excluded; no unexplained assumption of inclusion. |
| March 21 |
B→S servicing agreement |
Establishes S’s defined agency functions. |
Does not by itself make S the owner or establish its right to sue in its own name. |
| April 1 |
B asserts current ownership |
Both links, scope, and effective dates support the assertion. |
Future or later ownership does not prove an earlier claimed ownership date. |
Separate cash ledgers
Plain text
Consumer ledger:
Opening debt $1,050 − actual credited consumer payment $100 = $950
Acquisition ledger:
A pays O $120 for the asset.
B pays A $80 for the asset.
Total acquisition consideration across the two sales = $200.
Consumer credit from those sale payments under the stipulated sale terms = $0.
The purchase consideration is paid for transferred assets; the example stipulates no accompanying consumer release. It is not an additional consumer charge and is not deducted from the $950 merely because the asset sold at a discount.
Procedural alternative: if O had already commenced an action before transferring its interest, Rule 25(c) would require separate analysis. The title chronology alone would not establish that O must be dismissed.
Held conclusions: validity of either transfer, account inclusion, enforceability of restrictions, S’s permissible party role, and any actual plaintiff’s entitlement.
Authorities: S028 pp. 602–603; S036 ¶¶13, 22–30; S016 Rules 17(a), 25(c); S001 §44-144. Claims C019–C029, C083–C084.
M03 — Foundation at summary judgment versus contested trial
Actors: fictional Buyer B, Consumer Z, and records witness W. Valid current title is stipulated solely to isolate the records issue; the certificate itself does not prove title.
Fictional records and dates
- Ordinary account entries are made during April–June 2026.
- The file contains 120 entries. Whether they are sufficiently voluminous and inconvenient to examine individually remains a court question; 120 is not a legal threshold.
- July 15: a litigation summary is prepared from those entries.
- July 20: W signs a declaration describing actual knowledge and the relevant recordkeeping practices.
- The parties contemplate a later summary-judgment motion and, if necessary, trial. No procedural filing date or notice period is calculated.
Foundation matrix
| Proposition |
Positive evidence stipulated |
Missing-record or adverse branch |
| The electronic file is the claimed file |
Competent system/copy evidence or qualifying certification |
A hash or export label without the required explanation does not establish every proposition. |
| Entries meet Rule 803(6)(A)–(C) |
W can explain knowledgeable input, timing, regular keeping, and regular practice |
W knows only that a seller sent a spreadsheet. |
| W is qualified |
Actual familiarity with the systems and practices relevant to the records |
Position title and “I reviewed the file” are the entire foundation. |
| Predecessor information is reliable |
Competent explanation of how the predecessor records were integrated and relied upon, with actual source support |
Mere assertion that the seller was reputable. |
| Certification route is available |
Required certification, record access, and reasonable notice are established |
Notice, certification content, or inspection opportunity missing. |
| A Rule 1006 summary is offered as evidence |
Underlying material is admissible and available as required |
Missing or inadmissible source material cannot be repaired by the summary. |
| A chart is only illustrative |
Rule 107 conditions are satisfied |
Calling it “evidence” does not change its status. |
| Each hearsay layer has a basis |
Outsider statements are separately justified or offered for a nontruth purpose |
An embedded third-party email remains unexplained hearsay. |
Ledger
All amounts below are principal; interest and fees are stipulated at $0 for the modeled period.
Plain text
Supported opening principal: $800
New transactions: +200
Actual credited payments: −250
Supported returns: −50
Claimed ending principal: $700
Positive branch: with a complete supported opening balance and admissible records, the arithmetic totals $700. Liability, admissibility, and summary-judgment sufficiency still require their respective predicates.
Adverse branch: $400 of the opening $800 is merely an unexplained carried-forward figure.
Plain text
Documented-number subtotal:
$400 supported opening + $200 transactions − $250 payments − $50 returns
= $300
Unexplained opening component = $400
Claimed balance = $300 + $400 = $700
The $300 is not an adjudicated minimum recovery. Allocation, the cause of action, disputed transactions, and other liability facts can affect what the supported numbers prove.
At summary judgment, Rule 56 permits appropriately founded affidavits and admissible supporting material. At trial, the affidavit is not automatically a general hearsay substitute for testimony; an applicable certification, exception, stipulation, or other admissible route must support the offered evidence. Conversely, a properly established Rule 902(11) route can eliminate the need for live foundational testimony on the certified records.
Authorities: S008–S015; S016 Rule 56; S019; S027 ¶¶16–20; S029 ¶¶28–33; S035 ¶¶74–83. Claims C030–C049, C058–C064, C085–C086.
M04 — Settlement, provisional credit, reversal, replacement payment, and residual claim
Actors: fictional Creditor C and Consumer W.
Stipulated starting legal balance: principal $900, interest $60, authorized fees $40; total $1,000.
Stipulated settlement facts: a valid, authorized written pre-suit agreement freezes further additions and provides that $600 in cleared payments received by June 25, 2026 releases the remaining balance. This is an assumed existing agreement, not a drafted compliance form or a determination that any actual settlement has these effects.
| Fictional date/event |
Cash/credit event |
Principal |
Interest |
Fees |
Accounting balance |
| June 1, opening |
— |
$900 |
$60 |
$40 |
$1,000 |
| June 3, $200 clears |
−$200; stipulated allocation pays $60 interest, $40 fee, $100 principal |
$800 |
$0 |
$0 |
$800 |
| June 5, $400 provisionally credited |
−$400 provisional principal credit |
$400 |
$0 |
$0 |
$400 |
| June 7, that payment reverses |
+$400 restores principal |
$800 |
$0 |
$0 |
$800 |
| June 12, replacement $400 clears |
−$400 principal credit |
$400 |
$0 |
$0 |
$400 |
| June 12, stipulated release condition satisfied |
−$400 noncash release |
$0 |
$0 |
$0 |
$0 |
Plain text
Net cleared consumer cash:
$200 + $400 − $400 + $400 = $600
Accounting residual before release:
$1,000 − $600 = $400
Conditional balance after the stipulated valid release:
$1,000 − $600 − $400 = $0
There is no duplicate credit for the reversed $400. The $400 release is not a cash payment.
Adverse branches
- Receipt date or authority disputed: determine the actual recipient’s authority and the agreement’s payment/receipt terms. A processor’s possession or nonremittance does not by itself resolve whether the obligation was legally paid.
- Replacement payment clears after the contractual condition: the arithmetic residual is $400, but waiver, modification, release language, and the parties’ conduct remain unresolved. No automatic collectible $400 is declared.
- No valid release proved: a ledger showing $600 net receipts does not itself prove the claimed settlement defense.
- Debt later assigned: assignment does not create a new fee or automatically erase an established release defense; the applicable transfer and notice facts still matter.
- Discharge also asserted: bankruptcy scope and orders remain deferred. They are not inferred from this ledger.
The contractual date is fictional. No weekend, holiday, filing-calendar, or statutory deadline rule is being applied.
Authorities: S001 §44-144; S016 Rule 8(c); S008 Rule 408; S021 Rule 80(a) only if a disputed litigation agreement is actually implicated. Claims C026, C068–C070, C087–C088.
7. Source-currentness and interpretation reconciliation
| Version issue |
What was established |
What is not established |
| V01 — Credit-card statutes |
Current displayed §§44-7801–7806 were read and compared with the 2012 enactment; general effectiveness August 2, 2012 identified. |
No judicial transition holding deciding every older account or pending action. |
| V02 — Justice pleading verification |
Current §22-216 and the 2013 amendment/effective clause were read. Current signed-pleading language controls this report. |
No assumption that an older rule’s conditional reference to verification revives deleted statutory wording. |
| V03 — Business-record trustworthiness |
January 1, 2015 amendment places the specified untrustworthiness showing on the opponent after foundational predicates. |
No shift of the plaintiff’s ultimate merits burden. |
| V04 — Electronic proof/completeness |
Relevant 2018, 2019, and 2024 effective rule changes were read. |
No electronic-signature or certified-file safe harbor for identity, truth, or liability. |
| V05 — Summary evidence/opposing-party statements |
January 1, 2025 Rules 107/1006 and derived-party Rule 801(d)(2) amendment were read. |
The older Rule 1006 wording is not used as the current formulation. |
| V06 — Civil procedural consolidation |
Relevant 2017 baseline and 2024 Rule 56/55/80 changes were read. |
Full disclosure correction chain remains H03. Rule 80’s inconsistent petition-date recital is preserved, not silently repaired. |
| V07 — Memorandum citation |
Current selected Rule 111(c) text and the adopted January 1, 2027 future amendment were read. |
No full subsequent-history search or actual court permission to cite Eldred. |
| V08 — Federal provisions |
Official 2024 bodies and their notes were freshly read after failed current OLRC routes. |
No claim that October 27 access makes a 2024 edition a complete October 2026 currentness verification. |
8. Granular coverage and remaining-evidence table
8.1 Core coverage — 62 rows
Status: A = answered within stated scope/version; P = partial; H = held because necessary authority or facts are unavailable.
| Row |
Requested issue |
Status; claim references |
Exact remaining evidence or next action |
| G01 |
Express-contract elements |
A; C002 |
Actual agreement, breach facts, and damages evidence remain H02. |
| G02 |
Oral/implied contract |
P; C002, C009–C011 |
Applicable writing requirement, formation facts, and governing law; H01/H12. |
| G03 |
Open account |
A; C012–C013 |
Actual item-level proof and allocation; H02/H10. |
| G04 |
Account stated |
A; C014–C015 |
Receipt, finality, assent, and objections in an actual record. |
| G05 |
Equitable alternative |
A, bounded; C016–C018 |
Actual benefit, governing contract, and availability of legal remedy. |
| G06 |
Consumer versus business purpose |
A predicate; C001 |
Actual transaction purpose; mixed-purpose classification held. |
| G07 |
Choice of law |
H; C080 |
Contract choice clause, contacts, issuer law, and responsive choice-of-law authority. |
| G08 |
Debt validity versus plaintiff identity |
A; C002, C019, C022–C024 |
Actual formation and title evidence remain separate. |
| G09 |
Real party in interest |
A; C019–C020 |
Actual Rule 17 category and any ratification/substitution facts. |
| G10 |
Capacity |
A, narrow; C022, C052 |
Actual legal existence, representative status, and applicable entity law. |
| G11 |
Original-creditor posture |
A; C002–C008 |
Issuer/owner identity and applicable account terms. |
| G12 |
Single assignment |
A; C023–C024 |
Transfer intent, authority, scope, and identified obligation. |
| G13 |
Successive assignments |
A framework; C024, C083 |
Each actual chain link and account inclusion. |
| G14 |
Bulk sale versus account schedule |
A; C024 |
Competent connection between instrument and account-level material. |
| G15 |
Redactions and exclusions |
P; C024–C025, C046 |
Actual redacted text, exclusion terms, and completeness/protection ruling. |
| G16 |
Ownership dates |
A framework; C021, C024 |
Actual transfer/effective dates and litigation posture. |
| G17 |
Servicing/agency authority |
P; C028 |
Actual authority and representative-party predicate. |
| G18 |
Assignment and defenses |
A text; C026–C027 |
Notice-of-assignment facts and applicable statutory exceptions. |
| G19 |
Authentication |
A; C031–C032 |
Actual authenticity evidence and objections. |
| G20 |
Hearsay distinction |
A; C033 |
Purpose and content of each offered assertion. |
| G21 |
Personal knowledge/qualified witness |
A; C030, C035 |
Actual witness knowledge, competence, and foundation. |
| G22 |
Predecessor/integrated records |
P; C038–C040 |
Record-specific integration/reliance facts; no universal purchased-record exception found. |
| G23 |
Trustworthiness burden |
A; C036 |
Actual indicators of error or unreliability. |
| G24 |
Electronic contracts and attribution |
A framework; C009–C011, C089–C090 |
Actual acceptance logs, terms, retention, and attribution. |
| G25 |
Statements and payment records |
A framework; C005–C008, C012 |
Actual statement provenance, credits, and applicable terms. |
| G26 |
Evidentiary summaries |
A; C044 |
Underlying admissibility, volume, access, and accurate summary. |
| G27 |
Multiple hearsay |
A; C041 |
Basis for each actual layer. |
| G28 |
Objection preservation |
A, narrow; C048, C062 |
Actual ruling, objection, offer of proof, and court record. |
| G29 |
Pleading versus proof |
A; C050, C059 |
Actual pleadings and stage; no live response analysis. |
| G30 |
Verified denial/signed allegations |
A; C051–C052, C074 |
Applicable allegation and any additional statute requiring verification. |
| G31 |
Disclosure and discovery |
P; C053–C057 |
Full current superior disclosure correction chain; actual disclosures not sought. |
| G32 |
Summary judgment |
A selected rules; C058–C064 |
Actual admissible motion record and material disputes. |
| G33 |
Default amount proof |
A boundary; C065–C066 |
Actual default predicates and amount support; clocks remain deferred. |
| G34 |
Contested trial proof |
A framework; C002, C012, C030–C049 |
Actual admitted evidence and factfinder determinations. |
| G35 |
Small-claims evidence distinction |
A narrow; C067 |
Track eligibility and later local/retention procedures held. |
| G36 |
Interest/rate/fee authorization |
P; C007–C008 |
Actual lawful rate, issuer regime, terms, period, and charge basis. |
| G37 |
Payments, returns, reversals |
A framework; C012–C013, C068 |
Actual receipts, posting, legal credit date, and allocation. |
| G38 |
Settlement and release |
P; C068–C070 |
Actual agreement, authority, performance, waiver, and governing law. |
| G39 |
Mistaken identity/unauthorized use |
A framework; C004, C010, C072 |
Actual identity, authority, benefit, and issuer predicates. |
| G40 |
Discharge/other validity flags |
H; C068, C088 |
Actual order and applicable bankruptcy or other special law; deferred regime. |
| G41 |
Portfolio purchase discount |
A conditional; C029, C084 |
Actual sale terms or separate release could alter treatment. |
| G42 |
Allen |
A; C059–C060 |
No complete later-history certificate; current reply rule separately read. |
| G43 |
Eldred |
A as memorandum; C040, C071, C076 |
Citation-condition and federal-silence tension remain bounded. |
| G44 |
Published assignment authority |
A; C023–C025 |
Actual chain facts; no blanket documentary checklist. |
| G45 |
Published records authority |
A; C038–C039 |
Actual recordkeeping and witness foundation. |
| G46 |
Later material decisions |
A selected; C016, C025, C039 |
Full citator and all later decisions not checked. |
| G47 |
Subsequent history |
H |
Obtain permitted public published treatment, without live docket/private-record inquiry. |
| G48 |
Citation rule |
A selected; C076–C077 |
Any case-specific later citation limitation remains unverified. |
| G49 |
Statutory currentness |
P; C073–C075, C078 |
H04/H05/H12 and any materially applicable later enactment. |
| G50 |
Rule currentness |
P; C042–C047, C062, C077, C079 |
H03 and H13; no full consolidated-rule certificate. |
| G51 |
Failed-source handling |
A record; source failure ledger |
Recover only identified missing public bodies; no unchanged retrieval loop. |
| G52 |
Necessary federal overlay |
P; C071–C072, C078 |
Current OLRC body/later amendments; no broader FDCPA/TILA dossier. |
| G53 |
M01 contract/amount model |
A conditional; C081–C082 |
Actual lawful terms and records remain held. |
| G54 |
M02 chain/cost distinction |
A conditional; C083–C084 |
Actual instruments, schedules, dates, and agency proof. |
| G55 |
M03 evidentiary foundation model |
A conditional; C085–C086 |
Actual admissibility, record completeness, and judicial findings. |
| G56 |
M04 payment/release model |
A conditional; C087–C088 |
Actual settlement authority, clearance, and release terms. |
| G57 |
Distinct fictional postures |
A; P01–P20 |
No actual eligibility, debt, or litigation decision. |
| G58 |
Actual private records |
H |
No private records obtained or sought; remain outside authorization. |
| G59 |
County/local court practice |
H |
Applicable court and publicly promulgated local evidentiary/pretrial rules; no county practice validations performed. |
| G60 |
Tribal law/jurisdiction |
H |
Relevant sovereign, forum, parties, transaction, and law; no tribal rule imported. |
| G61 |
Interstate/federal-court boundaries |
H |
Choice law, jurisdiction, and governing federal procedural/evidence rules if applicable. |
| G62 |
Exact source/version metadata gaps |
P |
ChartOne exact issuance day, missing official images, UETA enactment, and correction-order bodies identified in H03/H05/H06/H13. |
8.2 Deferred families — nine rows
| Row |
Separate required component |
Disposition and exact next investigation |
| D01 |
Debt-management, CSO/CROA, provider fees, licensing, custody, trust funds, bonds |
Deferred. Investigate those regimes and actual predicates separately; no title or merits consequence inferred here. |
| D02 |
Collection credentials, communications, validation workflow |
Deferred except the narrow §1692g(c) evidentiary boundary. No P06/P07 conclusions imported. |
| D03 |
Court selection, venue, service, response clocks, default entry, vacatur, appeals |
Deferred except necessary pleading/SJ/default-amount clauses freshly read here. No P09 clocks used. |
| D04 |
Limitations, accrual, revival, judgment renewal |
Deferred. No P05 periods, dates, or holdings imported. |
| D05 |
Earnings, bank accounts, property exemptions, enforcement |
Deferred. No P03/P04 formulas or procedural conclusions imported. |
| D06 |
Secured debt, foreclosure, replevin, and sector-specific merits |
Deferred. Cases from other transaction settings used only for identified general principles. |
| D07 |
Arbitration, delegation, class waivers |
Deferred. No arbitration formation or enforceability determination. |
| D08 |
Full remedies, sanctions, fee shifting, representation, surety litigation |
Deferred. No damages award, litigation-fee entitlement, or actual representation permission. |
| D09 |
Complete local/tribal/federal/state/country/parent coverage |
Open. This pass supplies no statewide, parent, A066, A097, or A098 acceptance. |
9. Named hold register — 14 distinct holds
| Hold |
Exact missing evidence |
Consequence and next authorized research step |
| H01 |
Actual choice-of-law clause, transaction contacts, issuer law, and responsive choice-of-law construction |
Keep Arizona-law application conditional; research public controlling choice-of-law authority for a separately specified branch. |
| H02 |
Actual obligor identity, agreement, account, witness, and assignment records |
No actual liability, ownership, or sufficiency finding. Private-record inquiry remains outside this authorization. |
| H03 |
Full R-17-0010 corrective-order chain and current consolidated civil text |
Official index lists corrections dated September 14, October 12, October 26, 2017; March 30 and October 9, 2018. Obtain/read those public orders before certifying precise consolidated disclosure wording or schedules. |
| H04 |
Current readable OLRC §1692g/§1643 bodies and 2025–October 2026 amendment confirmation |
Federal discussion is anchored to fresh reads of the official 2024 edition; no later-currentness certificate. |
| H05 |
Original UETA enactment and exact transition chain |
Both S041 routes failed. Obtain an accessible official session-law reproduction; do not infer old-record coverage solely from creation date. |
| H06 |
Missing official opinion images and ChartOne’s exact issuance day |
Disclosed reproductions support identified holdings; obtain official/public bound-report material if exact image/date verification becomes necessary. |
| H07 |
Complete subsequent history, depublication, and later citation treatment |
No full citator claim. Continue only with public published legal authorities, not live docket/status queries. |
| H08 |
Record-specific foundation, integration, reliability, and witness competence |
No generic admissibility approval; each actual record and hearsay layer requires assessment. |
| H09 |
Applicable interest/fee authorization, rate, base, period, and issuer regime |
Keep I and F symbolic where unproved; do not substitute an unverified default rate. |
| H10 |
Actual payment authority, legal credit date, reversals, release, waiver, or discharge |
Cash arithmetic does not establish legal extinguishment or collectible residual. |
| H11 |
Applicable local, tribal, interstate, or federal procedural setting |
No local practice validation or state-rule application to federal/tribal litigation. |
| H12 |
Incorporated UCC definitions, special writing requirements, and transaction-specific statutory exceptions |
No generic application of §44-145, negotiable-instrument exceptions, guaranty rules, or special debt regimes. |
| H13 |
R-18-0041’s operative comment-amendment body |
404 followed by timeout. Do not repair S012’s federal-date commentary by invention; Arizona Rule 807’s read operative order remains separately identified. |
| H14 |
Current generic form revision/adoption and any actual court instruction needed for use |
No form was completed, adopted, or offered as a compliance instrument. Forms are unnecessary to the conditional models and remain unvalidated. |
10. Contribution crosswalk — preserving prior review limits
| Crosswalk row |
User-provided provenance/basis |
Contribution of PASS-10 |
What remains unaccepted |
| X01 |
Reviewed P01 retained: “Full agreements/funds/bonds/remedies and all other state categories stay open.” |
This pass addresses a narrow part of contract/account merits, plaintiff identity, assignment, and evidentiary proof. |
The quoted remaining-work status is preserved. No invented exact P01 merits row. |
| X02 |
Current litigation/judgment dimension is unaccepted and separately requires merits, ownership, evidence, and defenses. |
Supplies the source, claim, case, model, and gap registers above. |
No acceptance of the whole litigation/judgment dimension. |
| X03 |
Authorized parent requires broader state work. |
Conditional contribution only, with explicit currentness and factual holds. |
No state, country, parent, A066, A097, or A098 acceptance. |
| X04 |
P02 is separate; P03–P09 are saved or running but unreviewed according to the user. |
No earlier pass’s clocks, fees, ownership conclusions, case holdings, or actual status was used as a premise. |
Earlier raw reports and their review statuses are not rewritten or represented as verified here. |
The review-file statements above are user-provided provenance. I did not open or write coordinator files and do not claim a new review of the prior reports.
11. Count reconciliation and researcher self-check
Reconciled counts
| Register/category |
Count |
Counting rule |
| Source records |
43 |
S_AZ-P10-S001–S043 |
| Source records containing fresh body or index material |
40 |
Includes partial reads and official indices; does not mean 40 fully read operative documents |
| Failed/discovery-only source records |
3 |
S041–S043; recovered failures within other records remain in the failure ledger |
| Title 44 section-access rows |
19 |
All belong to S001; not 19 independent corroborating documents |
| Atomic claims |
90 |
S_AZ-P10-C001–C090 |
| Case/posture register |
11 |
Ten published opinions and one memorandum decision; these reuse source IDs |
| Core coverage rows |
62 |
G01–G62 |
| Deferred-family coverage rows |
9 |
D01–D09 |
| Total coverage rows |
71 |
Core plus deferred; comparison tables are not additional coverage |
| Named holds |
14 |
H01–H14; not additional completed components |
| Worked models |
4 |
M01–M04 |
| Distinct fictional postures |
20 |
P01–P20 |
| Contribution-crosswalk rows |
4 |
X01–X04; no duplicate accepted coverage |
Researcher self-check — not independent review
- I read the material statutory bodies, selected operative rule clauses and final amendments, and the relevant majority reasoning and dispositions identified in the source register.
- I did not read every page of the large rulebooks, every issue in the criminal opinions, every corrective rule order, or every later judicial treatment.
- I distinguished court-authored opinion text from host summaries, headnotes, added paragraph numbers, and a host’s “good law” badge.
- I did not count an authority merely quoted inside another opinion as a newly opened source.
- I treated Eldred as a memorandum and preserved both its record-specific reasoning and the §1692g(c) boundary.
- I kept current selected text, historical versions, future-effective Rule 111 language, the 2024 federal edition, and failed retrievals separate.
- The four models use disclosed fictional facts. Their arithmetic was checked; the stipulated interest rate, fee authority, ownership, records foundation, and settlement validity are not findings about any actual account.
- No actual person, entity, borrower, account, contract, property, license, live case, or docket was queried. No contact, filing, form submission, purchase, account change, website change, publication, new chat, or subagent was used for this pass.
- No local file write, independent review, comprehensive current-law certificate, actual collection permission, or state/parent acceptance is claimed.
END S_AZ PASS-10.