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Suued by a Debt Collector?
MEDLAND CREDIT MANAGEMENT, INC.
Plaintiff.
MS. JOE BLOW,
Defendant.
DEFENDANT'S ANSWER
Defendant Joe Blow answers the Complaint as follows:
1. Defendant admits only that the Court has jurisdiction as provided by law. Remaining allegations are denied.
2. Defendant admits name and residence.
3. Defendant lacks sufficient knowledge regarding Plaintiff's allegations concerning Social Security information and therefore denies.
4. Defendant admits if it is true, and denies.
5. Defendant admits Citibank issued the alleged account but denies all remaining allegations.
6. Defendant lacks sufficient knowledge to admit or deny the account number alleged.
7. Defendant denies the amount claimed.
8. Defendant Plaintiff has proven damages.
9. Denied.
10. Defendant lacks sufficient knowledge to admit or deny Plaintiff's allegation regarding the last payment.
11. Defendant denies Plaintiff has established compliance with the applicable statute of limitations.
12. Defendant lacks sufficient knowledge regarding ownership of the account.
13. Defendant denies.
14. Defendant denies Plaintiff has attached all documents necessary to establish its claim.
15. Denied.
Defendant denies every allegation not expressly admitted.
GENERAL DENIAL
Defendant generally denies each and every allegation contained in the Complaint not specifically admitted.
DEFENDANT'S ANSWER - 1
You Don't Need to Write a 30 page Document to Respond
THINK YOU NEED
YOU DON'T. I'M
10 YEARS, I'VE
DEBT COLLECTORS.
IS AN ANSWER
LAWSUIT.
MOST ANSWERS are only 2-3 pages
NOTICE SOMETHING? IT'S
ONLY TWO PAGES.
Respond to each allegation (claim)
MOST EVERYTHING ELSE.
IS JUST RESPONDING
TO THE ALLEGATIONS
ONE BY ONE.
YOU ADMIT WHAT'S
LIKE YOUR NAME
Admit
Deny
LACK KNOWLEDGE
DENY WHAT ISN'T.
IS TRUE,
YOU SIMPLY SAY,
LACK SUFFICIENT KNOWLEDGE.
THEN COMES THE
MOST IMPORTANT PART.
Affirmative Defenses
1. Failure to state a claim.
2. Lack of standing.
3. Failure to prove ownership of the debt.
4. Failure to prove the amount allegedly owed.
5. Failure to satisfy the statute of frauds exception.
6. Failure of consideration.
7. Payment, accord, and satisfaction to the extent applicable.
8. Preservation of additional defenses as discovery proceeds.
9. Arbitration pursuant to the governing Citibank Card Agreement.
PRAYER
WHEREFORE Defendant requests:
Plaintiff take nothing;
This Complaint be dismissed with prejudice;
Defendant recover allowable costs; and
the Court grant any other appropriate relief.
DEFENDANT'S ANSWER - 2
Now That Wasn't So Bad!
File That Answer!
OF STANDING,
FAILURE TO PROVE
OWNERSHIP OF THE
DEBT
THE AMOUNT OWED,
CREDIT CARD AGREEMENT
ALLOWS IT,
EVEN ARBITRATION.
THE BIGGEST MISTAKE
PEOPLE MAKE IS
ANSWER HAS TO
BE PERFECT.
IT DOESN'T. IT
BE FILED ON
I Have Answer Templates For Sale. Link in Bio.
DEBT LAWsuit STRATEGIES.
NEED ANSWER TEMPLATES,
THEY'RE IN MY
LEGAL SAMPLE PACK.
LINKEDIN, MY BIO.