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Subpoena for Documents to Escrow and Closing Company in Mortgage Fraud Case

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Subpoena re HOEPA Violations

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Memorandum in Support of Motion to Remand Rent-a-Bank Case to State Court

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Reply Memorandum in Support of Motion to Remand Rent-a-Bank Case to State Court

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Motion and Memo to Remand to State Court re Predatory Lending Scheme by Multiple Parties

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Individual Student's State Court Complaint Against School

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Individual Student's State Court Complaint Against School

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Private Student Loan Borrower's Complaint Against Proprietary School and Lender

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Complaint Alleging False Loan Claims From Trade School to Government

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Complaint re Trade School Fraud

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Consumer Defendant’s Counterclaims to Debt Buyer’s Suit

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Answer and Counterclaims re Old Credit Card Debt Purchased by Debt Buyer

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Certification of Facts Supporting Answer re Old Credit Card Debt Purchased by Debt Buyer

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Answer and Counterclaims to Credit Card Debt Action

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Answer and Counterclaims to Credit Card Debt Action

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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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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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Answer re Old Credit Card Debt Purchased by Debt Buyer

Sample Answer

This is a sample answer to a debt buyer's state court collection lawsuit alleging that no proof of a contract, the action is time-barred, the statute of frauds, no proof of ownership of the debt, lack of legal capacity, service of process, usury, and other defenses.  Sample document requests, deposition notice, interrogatories, and other pleadings in the same case are also available at this treatise's companion material.

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Consumer’s Answer to Debt Buyer’s State Debt Collection Suit

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Consumer’s Motion to Plead Defense of the Statute of Limitations in State Debt Collection Suit

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Complaint re Failure to Deliver Purchased Furniture

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Consumer's Response to Debt Buyer's Motion to Reinstate Complaint

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Reponse to Court Order re More Definite Statement

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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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Motion for Preliminary Injunction in Case Challenging Denial of Disability Discharge

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Homeowner’s Motion for Contempt for Failure to Cancel Deed of Trust in Automatic TILA Rescission Case

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Supporting Memorandum Supporting Contempt Motion in Automatic TILA Rescission Case

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Rule 26(f) Planning Meeting Report re Concert Facility's Wheelchair Accessibility

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Request for Production of Documents to CRA re Accuracy of Credit File

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Request for Production of Documents (to CRA)

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Document Demands to CRA re Repeated Inaccurate Reporting of Imposter's Data in Credit Report

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Document Demands to CRA re Repeated Inaccurate Reporting of Imposter's Data in Credit Report

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Document Demands to Bank Furnisher re Repeated Inaccurate Reporting of Imposter's Data in Credit Report

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Document Request to CRA re Impermissible Purpose

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Document Requests to Credit Reporting Agency re Fair Credit Reporting

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Request for Production of Documents (to Furnisher)

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Request for Production of Documents to Furnisher re Reinvestigation

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Document Requests to Contractor re Home Improvement Fraud

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Document Request to Lender re Undisclosed Repair History