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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.

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.