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Answer, Counterclaim, and Third Party Complaint

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Answer, Counterclaim, and Third Party Complaint re Foreclosure Defense

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Sample Answer and Counterclaim re Collection on Car Loan

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Answer re Discharge of Co-Signer's Obligation Due to Repossession Delay

Answer and Counterclaim to Deficiency Action

This is a model answer and counterclaims to an automobile creditor's deficiency action. Defenses include commercially unreasonable sale, a state statute limiting deficiencies, the absence of valid default and acceleration, strict foreclosure, violation of right to cure, and inaccurate calculation of the deficiency.  Counterclaims include conversion because of a defective security interest and failure to provide a right to cure, improper retention of personal property left in the car, breach of the peace in the repossession, various violations of UCC Art.

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Additional Counterclaims and Defenses Based on UCC § 9-615(f)

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Answer and Counterclaim re Unreasonable Sale and Defective Notice

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Homeowner’s Affidavit Stating Irreparable Injury If Foreclosure Injunction Not Granted

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Motion for Consolidation

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Response to Motion for Use and Occupancy

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Response to Motion For Use and Occupancy Pending Trial re Foreclosure Rescue Scam

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Application and Memorandum for a TRO and Preliminary Injunction

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Memo and Permanent Injunction re Scam by Foreclosure Assistance Company

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Motion for Injunction of Foreclosure Borrower in Temporary HAMP Modification

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Memo in Support of Injunction of Foreclosure Borrower in Temporary HAMP Modification

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Complaint by Homeowner Seeking TRO for Foreclosure Sale

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Answer and Counterclaim re Service Member's Repossessed Leased Car

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Answer and Counterclaim re Service Member's Spouse's Loan for Vacuum Cleaner

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Defendant's Answer to Class Complaint in Case re Alleged Fraud by Trade School

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Motion for More Definite Statement and Memo re Debt Buyer

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Motion for More Definite Statement and Memo re Debt Buyer

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Motion for More Definite Statement and Memo re Debt Buyer

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Objections to Card Issuer's Complaint

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Objection to Debt Buyer's Complaint for Lack of Documentation and Proof of Standing

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Objection to Debt Buyer's Complaint for Failure to Attach Adequate Documentation

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Consumer’s Motion to Strike Answer Filed by Debt Settlement Companies Without Using a Licensed Attorney

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Sample Answer to Collection Action (written by Consumer)

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Sample Answer to Collection Action (written by Consumer)

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Sample Answer to Collection Action (written by Consumer)

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Answer and Counterclaim re Identity Theft and Deceptive Debt Collection

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Answer and Counterclaims Against Debt Buyer and Collection Attorney for Filing Time-Barred Suit and Attaching a False Affidavit to the Suit

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Defendant's Answer Denying Credit Card Debt Owed

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Answer and Counterclaims Challenging Lease

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Answer and Counterclaim re Manufactured Home Repossession

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Answer re FHA Home Foreclosure

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Answer and Counterclaim re Predatory Mortgage

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Homeowner’s Affidavit in Support of TRO for Foreclosure Sale

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Notice to Take Deposition of Car Dealer re Yo-yo Sale, Undisclosed Wreck History

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Deposition Notice in Private Student Loan Case

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Deposition of Capital One Credit Card Accounts Recordkeeper re Records and Retrieval Systems

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Deposition of Debt Buyer Employee Who Signed False Affidavit

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False Affidavit Attached to Debt Buyer's Debt Collection Suit

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Deposition Notice in HAMP Loan Modification

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Deposition of Trans Union Employee re Changes in Information in Credit Reporting Agency File

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Deposition of TransUnion Employee re Reinvestigation Procedures and Quotas

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Deposition of Trans Union Employee re Reinvestigation Process and Procedures (Pt. 1)

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Consumer’s Arizona Civil Procedure Rule 26 Disclosures Where Prior Lienor Would Repossess Cars

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First Set of Discovery to Credit Union That Financed Used Cars With Preexisting Liens

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Second Set of Discovery to Credit Union That Financed Used Cars With Preexisting Liens

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Third Set of Discovery to Credit Union That Financed Used Cars With Preexisting Liens