What type of motion must be filed by the defendant in response? The defendant defaulted on the repayment obligation upon discovering that the services were not properly rendered. There are 2 counts: MONEY LENT/MONEY PAID & UNJUST ENRICHMENT. A credit card was used by the defendant.
The defendant needs to file an answer to the complaint. A defendant may also file a motion to dismiss based on what was pleaded in the complaint. If the motion is overruled however, the defendant must answer the complaint.
There is a difference between defaulting on the repayment obligation, and a default judgment. The defendant still has a right to dispute the debt, though it may seem clear cut to some. But he must assert his defenses, and dispute any facts in the complaint, in an answer.
Car / Auto Accident Lawyer
If you (or someone you know) are/is the Defendant, I'd advise you to speak with an attorney. A general civil or debtor/bankruptcy attorney may be able help you or the person you know reach a solution to the issues named in the complaint.
Disclaimer: This does not constitute legal advice. No attorney-client relationship has been formed through this answer.
Debt Collection Attorney
In response to a Complaint, a defendant must file a "Answer" (not a motion, with certain exceptions). It sounds like you would have defenses and counterclaims to raise along with the Answer. You should consult with an attorney to do this properly.