Well this what i came up with. Can the members review it and please let me know what I'm missing. Thanks
DEFENDANT'S ANSWER.
1. Plaintiff's paragraph one does not allege any claims and therefore no response is required but pursuant to its statements regarding its obligations under the Fair Debt Collection Practices Act, Defendant disputes the validity of the debt and demands strict proof thereof.
2. Plaintiff's paragraph two and three. Defendant denies allegation that I refused to pay the amount owned on the account or that I owes any amount of money to the Plaintiff and demands strict proof thereof.
WHEREFORE, premises stated, Defendant prays the Plaintiff take nothing by way of its petition or its prayer for relief.
AFFIRMATIVE DEFENSES
3. Some or all of the claims asserted by the Plaintiff are barred by the statute of limitations, laches, estoppel, unjust enrichment, unconscionable and/or unclean hands.
4. Defendant disputes the alleged debt and its amount are owed to the Plaintiff and requests debt validation.
5. Defendant has failed to provide an accurate accounting of the alleged debt.
6. Defendant does not owe the alleged debt to Plaintiff.
7. The plaintiff does not have standing to collect upon the alleged debt.
8. Defendant reserves the right to amend and/or add additional Answers, Defenses and/or Counterclaims at a later date.
Starting Score: 619