And not making payments
The best thing to do would be to hire a lawyer. It will be worth the investment. On your own, you will not be able to properly litigate a matter, especially if the plaintiff has an attorney.
There is no one universal "form" demurrer. You will have to make legal arguments to the court explaining why the complaint is subject to demurrer. If you are being sued, you should seriously consider hiring a lawyer to properly defend yourself.
Follow me on Twitter @joeroselaw. I answer questions on Avvo to try to help get you pointed in the right direction. But, I am not your attorney. Beware, my answers here are general, limited, incomplete, and can never be as complete, thorough, or accurate as one I would give to a client after hearing all of the facts and details of my client's situation and applying the correct law. Also, I am admitted to practice law only in California and all of my answers are intended exclusively for the Golden State.
Demurrers are almost always optional.
No legal advice here. READ THIS BEFORE you contact me! My responses to questions on Avvo are never intended as legal advice and must not be relied upon as if they were legal advice. I give legal advice ONLY in the course of a formal attorney-client relationship. Exchange of information through Avvo's Questions forum does not establish an attorney-client relationship with me. That relationship is established only by joint execution of a written agreement for legal services. My law firm does not provide free consultations. Please do not call or write to me with a “few questions” that require me to analyze the specific facts of your history and your license application and prescribe for you how to get a State license. Send me an email to schedule a paid Consultation for that kind of information, direction, and assistance. My law firm presently accepts cases involving State and federal licenses and permits; discipline against State and federal licenses; and disciplinary and academic challenges to universities, colleges, boarding schools, and private schools. We take cases of wrongful termination or employment discrimination only if the claims involve peace officers, universities or colleges.
I cannot think of any situation where buying a demurrer online would be good idea. Demurrers are seldom granted, and if granted, they are usually not dispositive of the entire action. Additionally, a demurrer is a very pleading and case specific motion. You really need an attorney to prepare this for you.