I need a little help!! summons response

[wudang]

Complaint from captial one/ rubin & debski p.a. (note: my account is charged off)

Allegation 1: this is an action for damages that does not exceed $5000.00, exclusive of interest, costs and attorneys fee’s

Allegation 2: the plaintiff est. a credit card account, bearing the # XXX, in the name of the defendant and issued a credit card to the defendent

Allegation 3: The credit card and the original credit card agreement (the “agreement”)were sent to the defendant. Upon information and belief , defendant is in possession of the original agreement. A copy of the agreement is attached and incorporated herein by reference

Allegation 4: Defendant, or others authorized by the defendant, used the account to incur charges, thus accepting the terms of the agreement and agreeing to be bound thereunder.

Allegation 5: defendant breached the agreement by failing to make payment when due.

Allegation 6:defendant owes plaintiff xx plus interest on the credit card account

Allegation 7:all conditions precedent to bringing this action have occurred or have been waived.

Allegation 8:Plaintiff is obligated to pay its attorneys fee for their services. Etc...

my response thus far is:

Allegation 1:

Allegation 2: Denied: Responding Party objects to this request on the ground that it is vague, ambiguous and unintelligible in that Responding Party has to speculate as to the meaning of "the credit card" and "the account."

Allegation 3:

Allegation 4: Denied: This request calls for admission of matter defendant has denied and thus it is improper.

Allegation 5:

Allegation 6: Denied: This request calls for admission of matter defendant has denied and thus it is improper.

Allegation 7:

Allegation 8:

FUTHERMORE, Defendant DENIES every other allegation not previously admitted, denied or controverted.

I would appreciate any help with completing my response.

Edited August 11, 2011 by wudang