Sample Motions, Forms, Affirmative Defenses

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Joseph Consumer


Case No._____________________


COMES Now Defendant, xxxxxxx, and files this Request for Production of Documents, and requests the Court to grant such Motion based on facts stated below:

“Document” means any written, recorded or graphic matter, whether produced, reproduced or stored on papers, cards, tapes, belts, or computer devices or any other medium in your possession, custody or control, or known by you to exist, and includes originals, all copies of originals, and all prior drafts. It includes all original business records, non-identical copies, computations, memoranda of oral or telephone conversations, tabulations, records of correspondence, notes made on other documents, microfilms, etc. A request to identify a document is a request to state as applicable:

1. The date of the document;

2. The type of document;

3. The names and present addresses of the person or persons who prepared the document and of the signers and addressers of the document;

4. The name of the employer or principal whom the signers, addressers and preparers were representing;

5. The present location of the document;

6. The name and current business and home addresses of the present custodians of the original document, and any copies of it;

7. A summary of the contents of the document; and

8. If the original document was destroyed, the date and reason for or

circumstances by which it was destroyed.

1. The alleged credit application from “”Account””, bearing the plaintiff’s signature;

2. The alleged credit agreement from “”Account”” that states interest rate, grace period, terms of repayment, et cetera;

3. Itemized statements or credit card statements from “”Account”” that demonstrate how the alleged amount of $X,XXX was calculated;

4. A contract, agreement, assignment, or other means demonstrating that XXXX. had the authority and capacity, and was legally entitled to collect on the alleged debt from “”Account””;

5. Letter(s) sent to plaintiff by XXXX., demonstrating an attempt to collect on the alleged debt, “”Account””;

6. A notarized statement, if presently existing or otherwise, by a person with original knowledge of the alleged debt, as it was constituted, and who can testify, or be so interrogated in a deposition, that the alleged debt was incurred legally;

7. Any and all further documents that you believe establish that plaintiff had an outstanding account or debt related to “”Account””;

8. Any further documentation, beyond what has been previously requested, that clearly establishes plaintiff’s liability and/or responsibility to the alleged debt;

9. Any and all written communication, received by the defendant from the plaintiff, regarding the reporting of the alleged account to any credit reporting agency, as well as defendant’s accessing of plaintiff’s credit report(s).

10. Any and all communications from defendant to the plaintiff explaining

why defendant reported the alleged debt to any credit reporting agency, as well as obtaining plaintiff’s credit report(s);

11. Any and all credit report(s) defendant obtained from any credit

reporting agency concerning the plaintiff;

12. Any and all notes, memoranda, or likewise, be they handwritten,

computerized, or typed, regularly kept in the normal transaction and

business of collecting debts, that relate to the plaintiff and/or


13. The defendant’s Articles of Incorporation;

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This is a pretty powerful tool, and a good preemptive strike. Most states allow it.


Joe Blow

Address 1

City, State ZIP

Phone (555) 555-1212



Case No.: XXXXXX


Investment Retrievers Inc.,



Joe Blow,




Comes now the Defendant Joe Blow, and files this Objection to Complaint, per California Civil Code Chapter 4 Section 430.30.


1. Defendant received the Plaintiff's Complaint on or about December 1, 2005. Defendant answered the complaint on or about December 28, 2005.

2. On or about January 17, 2006, Defendant filed a motion to strike because nearly all of the complaint contained false information (motion to strike complaint California Civil Code of Procedure 436 (a)).

We claim the false information based on the following facts:

(a) The Plaintiff has failed to provide any contract or agreement bearing the signature of the Defendant, nor any itemized statements or billing of said debts.

(B) Plaintiff has failed to provide a detailed list of the debts to the Defendant in the initial debt collection notice as require by the FDCPA and as evidence by case law. Coppola v. Arrow Financial Services, 302CV577, 2002 WL 32173704(D.Conn., Oct. 29, 2002) – Information relating to the purchase of a bad debt is not proprietary or burdensome. Debtor must phrase their request clearly to obtain: The source of a debt and the amount a bad debt buyer paid for plaintiff’s debt, how amount sought was calculated, where in issue a list of reports to credit bureaus, and documents conferring authority on defendant to collect debt.

© The Plaintiff has failed to provide any proof of a relationship between themselves and the alleged original creditor, specifically the authority of the Plaintiff to collect the debt on behalf of the original creditor.

3. On or about Feb 1, 2006, Plaintiff filed an opposition to the Defendant’s motion to strike. The hearing for the motion to strike was set for Feb 15, 2006.


4. The Defendant, in addition to the motion to strike, would like to file an objection to the original complaint based on California Civil Code of Procedure 430.10. The party against whom a complaint or cross-complaint has been filed may object, by demurrer or answer as provided in Section 430.30, to the pleading on any one or more of the following grounds:

430.10 (B) The person who filed the pleading does not have the legal capacity to sue.

430.10 (d) There is a defect or misjoinder of parties.

In regards to Section 430.30 (B), Incapacity to sue exists when there is some legal disability, such as infancy or lunacy or a want of title in the plaintiff to the character in which he sues. In this case, as stated in the motion to strike, the plaintiff has failed to provide a definitive relationship between themselves and the alleged original creditor of the alleged debt.

In regards to Section 430.30 (d), The legal definition of misjoinder of parties is the “joining as plaintiffs or defendants, persons, who have not a joint interest”. In this case, as stated in the motion to strike, the plaintiff has failed to provide a definitive relationship between themselves and the alleged original creditor of the alleged debt.

WHEREFORE, Defendant, XXXXXXXXXX, respectfully submits that the Court should dismiss or deny the Plaintiff's complaint, filed herein Palisades Collections, Inc. The Defendant prays for Dismissal of the complaint by the Plaintiff.

Defendant's Request submitted this ___________ day, of __________ 20__

What is the Colorado civil procedure code for the same thing?

Don't see it anywhere.

(I wish we had a list for every state in the USA's exact civil codes for this so all we had to do was look it up here. It is really hard to try and find it when your new to the legal arena.)

PS Thank you LUEser for the megapast. I think yours is also located here

I just meant for the specific civil code for each state reguarding California Section 430.30 ,so it isn't hard to look it up.I find it hard myself.

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Rules of Civil Procedure:


**IN Progress**



Note You have to register with this site.


**In Progress**




**In Progress**


Note this is a pdf file. Use Acrobat Reader.



**In Progress**






Note: This is a PDF File, use acrobat reader


Note: This layout is really awful, if someone could provide a more accessible version, that would be great!



**In Progress**


Note: This is a pdf document, use acrobat reader.


Note: This is a mitchie site, you have to navigate to the correct thread: Rules of Civ Pro. can be found under Maryland Rules-->[folder] Maryland Rules--> Title 2 and Title 3 for Circuit and District Courts respectively



Note: This is a pdf document, use acrobat reader.





Note: This site is a bit convoluted and harder than many to navigate.


New Hampshire:

Note: This is a pdf file, use acrobat reader.

New Jersey:

New Mexico:

**In Progress**

New York:

North Carolina:

Note: Use each individual PDF file or use the "consolidated chapter link" for the rules; this is a pdf file, use acrobat reader.

North Dakota:


Note: Ohio has a nice pdf set up with hyperlinks within the document.


**In Progress**




Rhode Island:

Note: This if for the District Court Rules, for other courts, please see the appropriate rules.

South Carolina:

South Dakota:


Also, Since I live in Tennessee, I've composed a PDF file for use offline hosted here:


Note: This is for the supreme court rules of Civ. Pro. For local rules, please refer to the appropriate statutes.



Note: Other statutes may be applicable.



Note: Limited Jurisdiction Court Rules-

West Virginia:


Note: These rules are for local circuit courts and are searchable by county.

General State Law:


**In Progress**

Federal Rules of Civil Procedure

PDF Link:

Also, This site may help you in your searches:

and this one:

and this one:


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A demurrer is a type of motion that can be filed with the court instead of filing an answer. The deadline for filing is the same as your answer. The arguments in this demurrer specifically address a complaint for breach of contract where no exhibits are attached. Generally, the contract is required to pursue a breach of contract claim, so they won't be able to proceed with their case until they present the contract to the court.

Here's the meat of the brief:



Defendant ______________ ("Defendant") respectfully submits the following Memorandum of Points and Authorities in support of her General Demurrer to Plaintiff Midland Funding LLC’s (“Plaintiff”) Complaint.

On ___________________, Plaintiff filed the instant suit for monetary damages in the sum of $____________. In its Complaint, Plaintiff claims this amount accrued under a written agreement between the parties. Plaintiff’s Complaint, however, is fatally flawed. Plaintiff neither attaches a copy of the purported agreement with Defendant to its Complaint, nor pleads any of the essential elements of the alleged contract. The lack of a contract or, alternatively, a recitation of its terms, leaves Defendant completely in the dark as to the basis of the claim being asserted against her by an entity which is completely unknown to her. Plaintiff conspicuously fails to provide information regarding the date the purported contract was entered into or even the subject of the contract (i.e., whether for goods, services, credit, etc.).

Not only does Plaintiff’s vague pleading fly in the face of the interests of justice, such pleading is prohibited by statute. As set forth in more detail below, Plaintiff has wholly failed to meet its statutory obligations under California Code of Civil Procedure [“CCP”] Section 430.10(e), and it is respectfully requested that the Court sustain Defendant’s demurrer without leave to amend since it appears that there is no reasonable possibility that Plaintiff can cure the fatal defects.


A. A Demurrer is Properly Sustained Where a Pleading Fails to State Facts Sufficient to Constitute a Cause of Action

A general demurrer is proper when the complaint fails to allege facts sufficient to constitute a cause of action. (CCP § 430.10(e).) To determine whether a complaint fails to allege sufficient facts, a demurrer must challenge defects that appear on the face of the complaint. (Id., § 430.30(a).) The “face of the complaint” includes matters shown in exhibits attached to the complaint and incorporated therein by reference and matters of which the court may take judicial notice. (Ibid.; Frantz v. Blackwell (1987) 189 Cal.App.3d 91, 94.) If upon consideration of all facts stated it appears that plaintiff is not entitled to the relief sought, the complaint or any causes of action therein will be held invalid. (Songer v. Cooney (1989) 214 Cal.App.3d 389, 390.)

It is well settled that a plaintiff must set forth specific facts in a complaint so that the defendant may plead intelligently and responsively to the pleading without having to guess or speculate as to the items of material or essential facts. (See Ankeny v. Lockheed Missile & Space Company (1979) 88 Cal.App.3d 931, 937.)

In the instant action, Plaintiff’s entire Complaint is subject to demurrer because it fails to state facts sufficient to constitute causes of action for common counts (First Cause of Action) or breach of contract (Second Cause of Action). (Code Civ. Proc. § § 430.10(e).)

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here's the rest of the brief (it wouldn't fit in one msg!)

B. Plaintiff’s Claims for Breach of Contract and Common Counts Fail as a Matter of Law

In order to make out a claim for breach of contract, Plaintiff must plead the contract, its performance of the contract or excuse for nonperformance, Defendant’s breach and the resulting damage. (Lortz v. Connell (1969) 273 Cal.App.2d 286, 290.)

Here, Plaintiff fails to plead the terms of the alleged agreement between the parties or to attach a copy of the alleged agreement to the Complaint. Instead, Plaintiff alleges a written agreement was entered not on a specific date but rather “within the last four years.” (See Complaint at p. __, ¶ ___.) Plaintiff then merely inserts the following boilerplate language claiming it constitutes the essential terms of this alleged contract:

“Plaintiff, or Plaintiff’s assignor, and defendants, and each of them, entered into a written agreement. By the terms of the said agreement(s), plaintiff provided defendants, and each of them, with [services rendered] and/or [goods, wares and merchandise] and/or [extension of credit] and/or [monies paid laid out or expended] at defendant(s) request.”

(See Complaint at p. __, ¶ ___.)

If the action is based on an alleged breach of a written contract, the terms must be set out verbatim in the body of the complaint or a copy of the written instrument must be attached and incorporated by reference. (Wise v. Southern Pacific Co. (1963) 223 Cal.App.2d 50, 59, emphasis added; Otworth v. Southern Pacific Transportation Co. (1985) 166 Cal.App.3d 452, 458-59.)

It is clear from the face of the Complaint that the above boilerplate language is not from any finalized written agreement but rather sample contract terms designed to be tailored to a specific agreement, hence the bracketed terms where the essential elements are meant to be placed. Not only is inserting language from some sort of sample contract inartful, Plaintiff's inclusion of the same highlights the falsity of its claims.

Similarly, under a cause of action for common counts on open book account and account stated, Plaintiff alleges as follows:

“By the terms of the said agreement(s), Plaintiff or Plaintiff’s assignor, provided defendants, and each of them, with services rendered and/or goods, wares, and merchandise and/or extension of credit at defendant’s special instance and request and in consideration thereof defendants promised to provide payment in the sum of $_________ and interest thereon which defendants and each of them failed to provide.”

(Complaint at p. ___, ¶ ____.)

Based on the foregoing, Defendant is wholly unable to ascertain whether a contract actually exists or what precise terms were purportedly breached. This wholesale failure to allege the verbatim terms of the contract, or to attach the agreement, thus renders Plaintiff’s breach of contract/common counts claim fatally defective.

C. The Demurrer Should be Sustained Without Leave to Amend Since There is No Reasonable Possibility Plaintiff Can Cure The Defects

A demurrer must be sustained without leave to amend absent a showing by the plaintiff of a reasonable possibility that the defect can be cured by amendment. (Blank v. Kirwan (1985) 39 Cal.3d 311; Lacher v. Superior Court (1991) 230 Cal.App.3d 1038, 1043.) The burden of proving such reasonable possibility is squarely on the plaintiff. (Torres v. City of Yorba Linda (1993) 13 Cal.App.4th 1035, 1041; Blank, 39 Cal.3d at 318; see also, Lacher, 230 Cal.App.3d at 1043.)

Here, Defendant’s demurrer should be sustained without leave to amend since there does not appear to be any reasonable possibility that Plaintiff can amend its Complaint to overcome demurrer. If Plaintiff, who presumably is aware it carries the burden of proof, possessed the alleged contract with Defendant, it is unlikely that Plaintiff would have simply neglected to attach it. Its failure to do so is evidence of the fact that no contract between the parties has ever existed. Its failure to plead the requisite “essential terms” of the alleged contract – let alone any of the terms whatsoever – is further evidence that no contract exists and that Plaintiff’s Complaint is without merit.

Having established that it does not have any written agreement with Defendant, and having established that it is not aware of when the purported agreement was entered into, whether it was for goods, services, credit or otherwise, Plaintiff cannot, in good faith, amend to cure such defects. Leave to amend should, therefore, be properly denied.


For the foregoing reasons, Defendant respectfully requests that the demurrer to Plaintiff's Complaint, in its entirety, be sustained without leave to amend.

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This is good if you get a summons and you don't have time to answer in the allotted time (in MA 20 days). I used this and the motion was allowed. I thought I needed a continuance, but what you are actually doing, is asking the judge if it's OK to break the rules (a leave) in connection with your answer. Then you ask for extra time. In my case he only gave 20 more days. To wit:


Comes now (your name), stating that:

1. The service of this Complaint was attested to by the (your County) Deputy Sheriff on xx/xx/0x.

2. An answer is required of defendant no later than 20 days, which date is xx/xx/0x.

3. Defendant requires additional time due to (your excuse which should sound pretty damn important).

4. Defendant submits attachment B, which serves as proof of same. (I attached a statement from a doctor).

5. Defendant requests an additional 90 days, or, notwithstanding, 60 additional days to answer Complaint.

6. Defendant contacted Plaintiff on xx/xx/x8 asking if Plaintiff would object to this motion. Plaintiff asked defendant to file the motion with the court.

WHEREFORE, I respectfully request a leave to file answer, and for all other just and proper relief. I affirm under the penalties of perjury that the foregoing representations are true.




Print your name


Mailing address


Town, State and Zip Code


I hereby certify that I sent a copy of this Petition by first class mail to the opposing attorney on _________________________.




Print your name

notagain xxheartxx

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This was my answer to Capital One. I'm in discovery now. I'll keep you posted on how things go. No response yet, but atty showed for Case Management. He didn't have the answer, just some alleged statements. Hope it helps someone.


(your county), SS.

(your) Court

Of (your jurisdiction)

Civil Action No. (your number)

Capital One Bank (USA), N.A.



(your name)



Defendant, appearing pro se, for its reply to the Complaint naming Capital One Bank (USA), N.A. plaintiff as follows: All answers correspond to the numbered paragraphs of the Complaint. All allegations of the Complaint are denied unless expressly admitted herein.


1. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment.

2. Admit.

3. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment.

4. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment.

5. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment.

6. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment.


1. (Law Office name) has not proven that they are authorized and licensed to collect claims for others in the State of (your state), or solicit the right to collect or receive payment of a claim of another.

2. (Law Office name) has not proven that they were retained by Capital One Bank (USA), N.A. as it’s representative in this matter.

3. (Law Office name) has not proven that Capital One Bank (USA), N.A. is the real party in interest. Defense demands proof of ownership, specifically that the alleged account is still the legal property of Capital One Bank (USA), N.A. with all of the original creditor’s rights and privileges intact.

4. Plaintiff's Complaint violates the Statute of Frauds as the purported contract or agreement falls within a class of contracts or agreements required to be in writing. The purported contract or agreement alleged in the Complaint is not in writing and signed by the Defendant or by some other person authorized by the Defendant and who was to answer for the alleged debt, default or miscarriage of another person.

5. Plaintiff failed to state a claim upon which relief can be granted. Plaintiff's Complaint and each cause of action therein fail to state facts sufficient to constitute a cause of action against the Defendant for which relief can be granted.

6. (Law Office name) has provided no sworn statement testifying to the accuracy or validity of their recollection of the alleged account.

7. Defendant alleges that Plaintiff is not entitled to reimbursement of attorneys' fees because the alleged contract did not include such a provision, and there is no law that otherwise allows them.

8. Plaintiff’s alleged damages are limited to real or actual damages only.

9. Defendant alleges that Plaintiff's actions are precluded, whereas Plaintiff's demands for interest are usurious and violate state and federal laws.

10. Defendant alleges that the granting of the Plaintiff's demand in the Complaint would result in Unjust Enrichment, as the Plaintiff would receive more money than plaintiff is entitled to receive.

11. Defendant reserves the right to plead other affirmative defenses that may become applicable and/or available at a later time, (for example, if a real party in interest is established for alleged account).

12. Defendant reserves the right to submit counterclaims that may become applicable and/or available at a later time, (for example, if a real party in interest is established for alleged account) including, but not limited to, violations of the Federal Truth in Lending Act, the Fair Debt Collection Practices Act, and the Fair Credit Reporting Act.

Defendant prays this case be dismissed with prejudice along with any further relief the court deems just and proper. Further the defendant sayeth not.

By the Defendant pro se

Dated: Month day, year

(Your name)

(sign here)

Your address

Your telephone

notagain xxheartxx

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PLEASE POST THE BEST SETTLEMENT OFFER WITH STIPULATIONS YOU HAVE HERE. If possible, it should be complete, and not just ideas like 'include a release'. We need suggested verbage for a complete settlement letter. Thanks.

I will start a thread about it, as well, to get as much interest as possible.

notagain xxheartxx

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[PDF] Florida M-Dismiss Jurisdiction -StandingFile Format: PDF/Adobe Acrobat - View as HTML

DEFENDANT'S MOTION TO DISMISS FOR LACK. OF SUBJECT MATTER JURISDICTION ... Florida courts rests exclusively in those persons granted by substantive law, ... -

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I am VERY new to this forum so if I am asking a question that has been asked and answered a million other times I apologize in advance.

My husband got served a summons for an unpaid credit card. The plaintiff is Citibank represented by Lustig, Glaser and Wilson, P.C.

What order do I file the documents in?

The Notice of Appearance

The Answer to the Complaint

The Sworn Denial

Should the Sworn Denial be sent in with the Answer to the Complaint?

How do I properly and legally submit the answers? Does it need to be certified mail?

Due to our financial situation we cannot afford an attorney so have to go this on our own. Any help will ge greatly appreciated!!!!!


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they have a great sample pack , that you buy here at the credit store,

(no instructions) is 8.95, will save you alot of time meandering around, you can use as a great SAMPLE, for your own needs. affirmitive defences.

debt validation samples, court case,debt settlement and more, well worth the money

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Admin , maybe you could help me , I do not understand how this forum works , how do I send in questions to you ? Above you posted various motions , would they be okay to use in Florida courts ? I have received Summons to Appear ( for pretrial conference / mediation ) I have sent Rubin & Debski ( I guess they are lawyers for Capial One Bank ) a Letter Of Demand for Validation by Certified Mail , If they do not send it I guess I will need to file a motion MOTION TO COMPEL DISCOVERY when I appear in court ?

Thank You David 9041

You would do much better by answering the summons before you find yourself with a default judgement.

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You stated ( You would do much better by answering the summons before you find yourself with a default judgement. ) I do not understand what you mean by answering the summons , it states that I need to appear 6 /17 /09 , I plan to appear and dispute the amount ( 2,603.13 plus interest ) when I called Rubin & Debski they stated the full amount was 4, 000. Dollars so I sent them the validation request . Does answering mean showing up ? Or is there more to it ?

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What exactly does the summons say?

You have posted in several other threads. There are answers in those threads.

Valdiation is out the window now that they have issued suit. The time for VOD was within 30 days of the dunning letter.

What have you done so far as regards answering the summons?

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Defendants, Pro Se

This Matter came before the undersigned,ex parte, on the motion of the Defendant for issuance of a subpoena duces tecum to XXX. .The Court having considered the motion and being fully advised, its is

ORDERED as follows

1. the motion is granted:

a copy of which is attached to this order



Judge/Court Commissioner

Presented by

defendants name , address and phone number

__________________________________________________ _______________







Defendants, Pro Se

I, X,Defendant Moves the court for issuance of a subpoena to X ,this motion is supported by the Declaration of X

YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or tangible things at the place, date, and time specified below (list documents or objects):


I,X ,declare as follows:

1. I am the Defendant in this Action

2.I am Requesting from X Provide to me the Following Documents identified in the proposed subpoena duces tecum

A .Name what you want here, copies, ect



3.Witness may Mail requested Documents to Defendant no later X days after recieving this subpoena

I Declare under Perjury under the Laws of the State Of X the Foregoing Statment is true

Dated in ,CITY< STATE < DATE, 2009

This Matter came before the undersigned,ex parte, on the motion of the Defendant for issuance of a subpoena duces tecum to

.XX .The Court having considered the motion and being fully advised, its is

ORDERED as follows

1. the motion is granted:

a copy of which is attached to this order



Judge/Court Commissioner

__________________________________________________ ___________

you need both sheets, i used this to get a copy of a phone record, just go in during court and the clerk will pass it to the judge for signing. the subpoena means." to produce tangible evidence for use at a hearing or trial.

"which seeks not so much the appearance of a person before a court of law, but the surrender of a thing (eg. a document or some other evidence) by its holder, to the court, to be available if required as evidence in a trial."


you can use this to get your own documents if the CA isnt providing them to you,( can use for the OC records,, phone records (A hint here) say the CA calls way to often,, well you "could" use this to get the records showing just HOW many times they called from thier phone carrier/ provider, and a reverse look up sometimes shows whos the Provider of the number . and watch them Cr*p when you have thier Own records , ooh so hard for a CA to say we did not,, when you have that in hand..

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Wow this is awesome information. I used to be a litigation para in NYC and now my husband is being sued by Altantic Credit. I drafted a motion to dismiss the complaint because they are suing him the a county in which we do not live. We receive all our mail at a PO Box and Plaintiff filed docs with the court and sent them to our home address where we don't get mail. I found out that the docs were filed online. Is there some kind soul out there who might take a peek at my motion. I'm open to criticism because I haven't done this since 1996. I have a diabetic 10 year old who needs my full attention and this is going to make me snap. Help please:)

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