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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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