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Showing results for tags 'debtor'.
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Please let me know if my response to summon is correct 1. the claim herein has been assigned to Plaintiff for collection, (answer: Defendant objects to this request on the ground that the Defendant has no way of knowing if this claim has been assigned to plaintiff for collection.) 2. Plaintiff is a Washington Corporation in good standing, is duly licensed and has satisfied the Bonding requirements of the state of Washington. (answer: Defendant objects to this request on the ground that the Defendant has no way of knowing if Plaintiff is a Washington corporation in good standing, is duly licensed and has satisfied all bonding requirements. ) 3. During all material times defendants above were and are married and the obligation hereafter pleaded is the community and separate obligation of each. (answer: Defendants are subject to the jurisdiction of this court) 4. Defendants are subject to the jurisdiction of this court. (answer: Plaintiff’s complaint is not properly verified and is not grounded in fact because it does not exhibit the alleged contract the debt is based upon, a valid statement of account, nor any valid assignment that gives Plaintiff legal title to the claim. ) 5. Defendants became indebted to NW SURGICAL SPECIALISTS for certain goods or services which assignor is duly licensed to render, upon which there remains a balance of $941.64 which has been demanded without avail plus statutory interest from 7-31-14 to date of judgment. (answer: Plaintiff’s complaint is not properly verified and is not grounded in fact because it does not exhibit the alleged contract the debt is based upon, a valid statement of account, nor any valid assignment that gives Plaintiff legal title to the claim. ) 6. The reasonable value of the goods or services furnished to the defendant by plaintiff's assignor(s) is $941.64. (answer: Plaintiff’s complaint is not properly verified and is not grounded in fact because it does not exhibit the alleged contract the debt is based upon, a valid statement of account, nor any valid assignment that gives Plaintiff legal title to the claim. ) Respectfully Submitted, WHEREFORE, Defendant prays that this Court find judgment for Defendant, deny Plaintiffs’ request for the relief , deny Plaintiffs’ request for interest, deny Plaintiffs’ request for costs, deny Plaintiffs’ request for attorney’s fees and deny Plaintiffs’ request for any relief. Defendant further prays that this Court hold that Defendant is the prevailing party, and dismiss Defendant with prejudice.