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. 9,  Truth in Lending, UDAP,  debt collection harassment, and claims concerning the underlying sales transaction.