Did he receive a summons? If it's past the SOL, state that in the response to summons, copy the court CMRRR too. I was caught by a JDB that I HAD responded to, though not in their proper form...so they filed a bogus "non-response affidavit" and got an automatic default judgment.
If this is the OC I would handle it this way, if it's a CA, request DV also with the Summons.
Good luck!!
Don't trust that lawyer, yes he knows but people are buying old accounts, scaring people because most consumers do NOT know their rights so they pay!