please help - need form for dismissal in michigan

[ConfusedButLearning]

I reviewed the sample forms in the sticky and the one that most applies for my case is the dismissal of claim.

I went to this site for the courts in my state

http://courts.michigan.gov/scao/courtforms/

but really can't find anything appropriate to appeal the claim.

Does anyone know what form I would use in michigan that closely resembles the dismissal of claim sample for ca in the sticky. This is on a request for judgement from a collector that brought the assets from the original creditor.

I want something that cites the FDPCA.

[ConfusedButLearning]

I modified the form from the sticky, do you see any issues with using this in Michigan.

State of Michigan

24th Judicial District

Judicial Circuit

Case No. xx-xxx-xxx

Motion to Dismiss Complaint

NCO Portfolio Management

Assn for CITIBANK

xxxxx Law Firm

xxxxxxxxxxxxxxxxxx

W. Bloomfield Mi xxxxx

Plaintiff

Vs.

xxxxxxxxxxx

Defendant

MEMORANDUM OF POINTS AND AUTHORITIES

Comes now the Defendant xxxxxx, and files this Request for Dismissal of Complaint, as follows:

1. The Causes of Action specified in the complaint filed by the Plaintiff is insufficient as a matter of law.

The complaint does not set forth the True facts upon which Plaintiff seeks a summary judgment. Principal last payment date , and outstanding amount are disputed. The complaint should be dismissed.

2. Defendant received the Plaintiff's Complaint on or about April 19, 2007. Defendant answered the complaint on or about April 29, 2007.

3. 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. .

4. The plantiff has failed to acknowledge or address the previous arbitration order for dismissal.

5. 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.

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

WHEREFORE, Defendant, xxxxxx , respectfully submits that the Court should dismiss and deny the Plaintiff's complaint, filed herein , . and prays for Dismissal of the complaint by the Plaintiff.

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