In filing the general denial, do I answer the areas of the complaint where they specifically mention causes? For example, in the summons they sent me there are two sections and titled as follows:
FIRST CAUSE OF ACTION: ACCOUNT STATED
15. Plaintiff alleges and incorporates by reference the foregoing paragraphs
16. Within the last four years, an account was stated in writing between Defendant and SYNCHRONY BANK and on the account a balance of $xxxx.xx was stated to be due to SYNCHRONY BANK from Defendant. Defendant expressly or impliedly agreed to pay SYNCHRONY BANK that balance. Attached hereto as Exhibit B is a true and correct copy of a billing statement showing the balance due and owing $xxx.xx
17. Before the commencement of htis action, Plaintiff was assigned the credit account and indebtedness. Plaintiff is now the owner and holder of this credit account.
18. Plaintiff has made demand on Defendant for repayment of the credit account, but Defendant has failed to pay the balance due.
19. Payments, set-offs, credits or allowances, if any, at or after charge off, have been posted to the credit account.
20. The current balance presently due and owing is $xxx.xxx
SECOND CAUSE OF ACTION: OPEN BOOK ACCOUNT
21. Plaintiff alleges and incorporates by reference the foregoing paragraphs.
22. Within the last four years, Defnedant became indebted to SYNCHRONY BANK on an open book account for money due in the sum of $xxx.xx for money lent, paid, laid out, and/or extended to or for Defendant and Defendants special instance and request and for which Defendant agreed to pay the above sum.
23. Before the commencement of this action, Plaintiff was assigned the credit accoutn and indebtedness. Plaintiff is now the owner and holder of the credit account.
24. Plaintiff has made demand on Defendant for repayment of the credit account, but Defendant has failed to pay balance due.
25. Payments, set-offs, credits or allowances, if any, at or after charge off, hve been posted to the credit account.
26. The current balance presently due and owing is $xxx.xxx
WHEREFORE, Plaintiff prays for judgement against Defendant as follows:
1. For the current balance presently due ad owing of $xxx.xx
2. Costs of suit; and
3. Any such other relief as the Court may deem just and proper.
So here's some background on the suit. When Portfolio first wrote me, I asked them to verify the debt in writing which they responded to and sent me a set of statements. In this summons, they attached Exhibits A and B that are Amazon CC (synchrony bank) statements w/the balance, my name and amount due. After they responded to me initially, I sent them (the lawyers Hunt & Henriques) another certified letter asking for a repayment plan of $100/month and they opted to ignore that and instead went ahead with their law suit.
What points above would I address in the general denial form, would I simply deny every single item above or what? Also, if I want to instead settle with them (e.g. rather than go the MTC/court route) and offer them for example half the balance due, how would I do this?